Chapter 48 – Aviation Safety

Contents

Approved by Kevin Goodwin
Revised 7/23

48.0 Policy Introduction
48.1 Scope and Applicability
48.2 Exceptions
48.3 Roles and Responsibilities
48.4 Definitions
48.5 Operational Requirements

• 48.5.1 Standards of Performance
• 48.5.2 Research and Non-Research Aircraft Operations
• 48.5.3 Aviation Safety Plans
• 48.5.4 Project Review and Approval Process
• 48.5.5 Unmanned Aircraft Systems
• 48.5.6 Unmanned Free Balloons
• 48.5.7 Moored Balloons and Kites
• 48.5.8 Commercial Aviation Services (CAS)

48.6 Training Requirements
48.7 Procurement Requirements
48.8 Maintenance Requirements
48.9 Reference Documents
48.10 Appendices

• Appendix A. Training and Certification Requirements for UAS, Balloon and Kite Flight Crew Members
• Appendix B. Risk Assessment for UAS, Balloon and Kite Operations
• Appendix C. Logging sUAS (Drone) Flights
• Appendix D. UAS (Drone) Flight Crew Responsibilities
• Appendix E. Aviation Safety Plan Example
• Appendix F. UAS Notification to HQ OAM Senior Aviation Manager (Form 19)
• Appendix G. Notice to Airmen (NOTAMs)
• Appendix H. Pre-flight Checklist for UAS
• Appendix I: FAA Advisory Circular AC-107-2
• Appendix J. Accident Reporting Requirements
• Appendix K. Responding to Suspicious UAS or Other Aviation Activity
• Appendix L. Summary of U.S. Department of Energy COA
• Appendix M. U.S. Department of Energy Certificate of Waiver or Authorization: Class G – Public Agency sUAS COA “2021-ESA-9226-COA (Complete COA)
• Appendix N. LBNL’s Public Airspace Operations Declaration Letter
• Appendix O. Constraints on the Use of Low Altitude Authorization and Notification Capability (LAANC)
• Appendix P. Future Forms and Exhibits
• Appendix Q. University of California (“UC Drones”) Resources
• Appendix R. Remote Identification of Drone UAS
• Appendix S. Interacting with the Public
• Appendix T. Richmond Field Station Practice Facility
• Appendix U. Remote Pilot Certificate Renewal Program
• Appendix V. Current DOE and LBNL Aviation Safety Contact Information

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48.0 Policy Introduction

This chapter establishes policy regarding aviation safety at Lawrence Berkeley National Laboratory (LBNL). It provides procedures and guidelines that help ensure research and non-research activities involving aviation are safely executed and remain compliant with the requirements set forth in Department of Energy (DOE) Order 440.2C (September 15, 2020) Aviation Management and Safety and Federal Aviation Administration (FAA) 14 CFR Part 107 Operation and Certification of Small Unmanned Aircraft Systems regulations, among other FAA requirements.

This Policy commonly includes links to FAA websites, which are continually revised. FAA requirements will be applied in those cases where DOE requirements do not provide specific direction.

In addition to describing LBNL’s policy regarding aviation safety, this document serves as the Berkeley Site Office (BSO) Aviation Implementation Document (AID) for LBNL.

General Safety Considerations

Aviation operations – manned and unmanned – present the potential for serious injury, death, and/or environmental/property damage. It is essential that operations, which LBNL employees lead or participate in, are performed in the safest practicable manner. The safety of personnel while participating in aviation activities and/or utilizing Commercial Aviation Services (CAS) supersedes all other project objectives.

LBNL personnel are required to plan missions from a standpoint of safety. Should there be any doubt concerning the safe completion of a flight operation, every alternative method must be considered, including cancellation of the project. All operations must be formally authorized, and conducted in compliance with this Policy and applicable local, State or Federal regulations.

Department of Energy – Order 440.2C

DOE Order 440.2C establishes significant review, risk analysis, and reporting requirements. It regulates contractor aviation operations, including those involving unmanned aircraft systems (UAS).

LBNL personnel conducting manned or unmanned aircraft flight operations and/or using CAS must ensure that the requirements contained in DOE Order 440.2C and described in this chapter are met and that associated risks are assessed (see Appendix B and Appendix I).

Unmanned Aircraft Systems

Federal Aviation Administration (FAA) 14 CFR Part 107 establishes comprehensive requirements for operating UAS. The operation of UAS comprises the primary, but not only, focus of this chapter. The requirements set forth in this Policy apply to a broad range of unmanned aircraft types in addition to drones, including moored balloons, unmanned free balloons, and kites.

LBNL personnel conducting unmanned aircraft flight operations must ensure that the requirements contained in FAA 14 CFR Part 107 or the DOE nationwide COA (and described in this chapter) are met and that associated risks are assessed. Comprehensive information regarding UAS can be accessed at the FAA Unmanned Aircraft Systems Portal. In addition, the LBNL Aviation Point of Contact (APOC) is available to support LBNL staff in successfully navigating unmanned aircraft requirements. See Appendix V. for contact information for the APOC and other key aviation personnel.

Commercial Aviation Services

This Policy also addresses the requirements for using Commercial Aviation Services (CAS) to support research and non-research activities. The use of a CAS must be addressed in the Work Planning & Control (WPC) Activity for the project deploying CAS. Only CAS specifically approved by the DOE Office of Aviation Management (OAM) may be used during the course and scope of conducting research and non-research operations at LBNL. LBNL employees must select a CAS from the DOE Accepted Operators List when a scheduled commercial air carrier is not available to provide transportation. In the event an accepted CAS is not available, contact the APOC for assistance. See Section 48.1.8 for further information.

Other Aircraft Types

Other aircraft types, specifically unmanned free balloons, moored balloons and kites, are addressed in this Policy. See Sections 48.5.6 and 48.5.7 for additional information.

Reviews and Authorizations

Research and non-research aviation operations must be reviewed by the LBNL Aviation Point of Contact (APOC). Additionally, operations involving the use of UAS require review by the DOE Berkeley Site Office Aviation Safety Officer (ASO) and the OAM. All operations involving the use of manned and unmanned aircraft must be authorized per LBNL’s Work Planning & Control (WPC) program.

Aviation Safety Plans (ASP) are the primary means for planning, vetting, and approving research or non-research flight operations involving UAS, including drones, moored balloons, unmanned free balloons, and kites. An ASP provides a detailed description of project objectives and outlines the risks associated with planned flight operations. The ASP contains the core documentation that informs the WPC Activity for the project.

Federal Aviation Interactive Reporting System (FAIRS) Reporting Requirements

All activities, costs and inventories associated with CAS, Non-DOE owned UAS regardless of value, and Federally owned aircraft, (including UAS) with value greater than $500,000.00, must be reported via FAIRS. The APOC will support FAIRS reporting at least annually for required aviation activities/costs/inventories except CAS which must be reported quarterly. If no CAS activities occur, FAIRS reporting is not required.

Limitations

This Policy does not apply to situations involving aircraft responding to medical or other emergencies on site. In those rare cases, operational decisions (including choice of landing site) will be deferred to LBNL’s site security authority. LBNL does not provide on-site facilities for rotating wing (helicopter) or fixed wing (airplane/glider) maintenance and operations.

48.1 Scope and Applicability

The scope of this chapter is all aircraft operations at LBNL including (but not limited to) manned aircraft, drones, moored and free balloons, kites, and small UAS (drones). The chapter applies to all LBNL employees, affiliates, and commercial aviation service (CAS) providers contracted by LBNL. This chapter also serves as BSO’s Aviation Implementation Document (AID) for LBNL.

48.2 Exceptions

Requests for exceptions to this chapter must be made to LBNL APOC and approved by both the ASO and the ASM. The LBNL APOC will vet requests for exception and then forward them first to the ASM and the ASM forwards the request to the ASO. This process can be expected to take on the order of 4 weeks.

48.3 Roles and Responsibilities

Aviation safety roles and responsibilities at LBNL derive from DOE Order 440.2C and FAA Part 107 regulations. Starting with the DOE Office of Aviation Management, those roles and responsibilities are as follows:

Position (Role)	Responsibilities
Director, Office of Aviation Management	Designated as the Senior Aviation Management Official (SAMO) for the Department of Energy in accordance with the requirements of Title 41 CFR Part 102-33. See DOE Order 440.2C Page 8 for the responsibilities of DOE elements.
DOE/NNSA Aviation Board of Directors	Composed of representatives from each field element, specifically aviation managers and safety officers who recommend broad policy and procedures for the operations and safety of Federal aircraft and  services to the Chair of the Aviation Board. The Board of Directors’ major function is to review, deliberate, and process Policy change recommendations before they are submitted for implementation.
Director, Office of Science (Head of DOE/NNSA Element that oversee, manage, operate, or maintain DOE/NNSA-owned aircraft or acquire CAS aircraft within their programs)	The Director, Office of Science must: Develop and implement effective aviation operations, airworthiness, security and safety programs that meet the requirements of DOE Order 440.2C. Identify the contracts to which the Contractor Requirement Document (CRD) applies and notifies the contracting officers to incorporate the CRD into the affected contracts via the laws, regulations, and DOE/NNSA directives clauses included in those contracts. In the case of contracts requiring contractor performance of activities set forth in the CRD, but which do not contain the laws, regulations, and DOE/NNSA directives clause, notify the contracting officers of these requirements; and 10 DOE O 440.2C Appoint a Federal Aviation Manager or Federal ASO or both, depending upon the size and scope of operations, number of aviation operations conducted or aircraft assigned and appoints a person to the DOE/NNSA Aviation Board of Directors.
Office of Science (DOE Element) Aviation Manager (AvM): Gus Fadel, Office of Science, Aviation Safety Manager Note: For listing of DOE departmental elements, see https://www.directives.doe.gov/references/doe_departmental_elements	Establishes goals for the field aviation program based on the anticipated requirements as applicable to DOE/NNSA, the field element, and other DOE/NNSA organizations that may require aviation services. Implements DOE/NNSA aviation management and safety policy and establishes the field element’s standards for the aviation program that will ensure an effective, safe, secure and cost-efficient operation in accordance with this Order. Develops the organization’s Aviation Implementation Documents (AID) and annually reviews the AID to ensure that it is current. Provides direction to DOE/NNSA contractors performing aviation-related services, via the appropriate designated representative in accordance with the contract statement of work and/or the CRD included in the contract. This includes the types of missions that are required and the regulations, policies, and standards that contractors are to follow. Provides revised AID to contracting officer or designated representative as necessary to ensure revisions to contractor written aviation programs as required by the statement of work and/or CRD. Additional responsibilities of the AvM are detailed in DOE Order 440.2C 11 6-15-2011, pages 10 and 11. See https://www.directives.doe.gov/directives-documents/400-series/0440.2-border-c-chg2-ltdchg/@@images/file
Berkeley Site Office (Field Element) Aviation Safety Officer (ASO)	Gathers, trends, and analyzes aviation safety performance data to ensure the safety of the field aviation program. Conducts periodic assessments of aviation activities to ensure that requirements, policies, and procedures are implemented and followed and prepares reports documenting assessment findings, concerns, and recommendations and tracks corrective actions to help prevent similar occurrences. Participates as directed in aviation accident or incident investigations and provides assistance to accident investigation boards during their investigations. Identifies and reports safety concerns to the AvM when he/she believes that the field element manager’s intervention is required and works to eliminate potential hazards. Develops ASR and/or ASD as required by paragraph 10 of this Order, or in the case of a contractor operated aviation element, reviews and concurs on ASRs and ASDs. ASDs will address potential hazards associated with the activity and methods to mitigate these hazards. Ensures that aviation personnel report mishaps, hazards, and concerns to the Occurrence Reporting and Processing System (ORPS) or the Aircraft Accident Incident Reporting System (AAIRS). Participates in the Aviation Safety Awards Programs to ensure that organizations and personnel are recognized for their contributions toward providing the Department with a safe aviation program.
Flight Readiness Review Board (FRRB)	The purpose of an FRRB is to evaluate the safety, design, operational planning, and functional adequacy of the aircraft operations that are not already regulated by other Federal regulations, or those that may deviate from DOE Order 440.2c or other DOE/NNSA standards. Prior to the initiation of flight operations, conduct an independent review of the total project to assure that adequate planning and preparation have been accomplished to achieve the desired results under acceptable safety conditions. FRRB’s are appointed by the AvM as needed for projects that require special analyses and review.
LBNL Environment, Health and Safety Division (EHS) Director, and Senior Division Leadership	Responsible directly, or via a designee, for ensuring full and effective implementation of Aviation Safety Program policies and procedures.
LBNL Aviation Point of Contact (LBNL APOC)	The primary LBNL contact for matters related to aviation safety.  Responsible for aviation safety-related policy development, guidance, program assurance, and approval of Work Planning & Control Activity documents.  Reviews request for Commercial Aviation Service (CAS) / Unmanned Aircraft Systems (UAS) procurement. Communicates DOE, FAA, and Berkeley Lab requirements to the requestor. Specifically, the LBNL APOC: Ensures that the LBNL aviation safety program (this ES&H Manual and RPM chapters) is adhered to by all LBNL staff, CAS, subcontractors, etc. Reviews the LBNL aviation safety policy/program at least annually. Modifies the plan as needed to ensure and enhance its effectiveness. Assists the ASO as requested in completion of his or her responsibilities noted above. Ensures that a monthly spreadsheet report to the SAMO is emailed in a timely manner (by the 10th of each month), based on input from RPICs. Reviews and approves WPC documents for each principal investigator conducting flights. Reviews and approves Aviation Safety Plans for each laboratory activity conducting flights. Tracks RPIC FAA Remote Pilot Certificate status, checking the training and qualification of the RPIC and VO. Note: The above responsibilities may be delegated to appropriate specific individuals by the APOC.
LBNL Line Management (e.g. Division Manager)	Ensures that LBNL staff, including affiliates adhere to this policy, including and especially including all aviation activities in the appropriate WPC. See: https://www.lbl.gov/laboratory-organization-chart/.
Environment, Health and Safety Division (EHS) Liaison	Person within a Division with the responsibility of coordinating with the Environment, Health and Safety Division (EHS), usually the Division Safety Coordinator. (DSC). Coordinates with the APOC as needed and ensures that all aspects of project safety are appropriately represented in the WPC, including aviation activities.
LBNL Field Site Manager (FSM)	FSM is a staff member responsible for all LBNL- or DOE- funded activities at a specific field site.
LBNL Principal Investigator (PI), Field Site Manager or Designee (also referred to as “Requestor”)	PI’s contact Berkeley Lab Aviation Point of Contact (LBNL APOC).  Prepares the Aviation Safety Plan (ASP) including safety analysis and airworthiness documents.  Completes and submits FAA Certificate of Authorization request and documentation. Completes Berkeley Lab documentation via WPC. Conducts work in accordance with Policy. The applicable Principal Investigator, Field Site Manager or designee (Requestor) is responsible for the following: Ensures that WPC documents including the ASP required for UAS operations are approved and current. Verifies the training and qualification of the RPIC and VO. Coordinates with the RPIC for Notices to Airmen (NOTAMs; see Appendix G). Serves as the point of contact (POC) for users conducting UAS operations at the field site. Coordinates any site infrastructure needed by users to conduct UAS operations, including frequency spectrum approval. Reviews monthly flight reports generated by the LBNL APOC or his designee to verify accuracy. Assists the LBNL APOC in ensuring compliance with this chapter. Establishes the science objective for each flight and conveys the objectives to the RPIC. In conjunction with the RPIC, determines the flight paths needed to safely achieve the science objectives. In conjunction with the RPIC, establishes both the minimum and optimum weather requirements for flight in advance of the campaign. Verifies and monitors payload operability and data transmission before and during flight as applicable. Provides input/requests to the RPIC during each flight regarding changes that may be needed in the flight pattern (e.g., altitude; loitering) to facilitate achieving the science objectives.
LBNL Remote Pilot in Command (RPIC)	The Remote Pilot in Command (RPIC) is directly responsible for and is the final on-site authority as to the operation of the UAS. The RPIC also is responsible for compliance with Aviation Safety Program requirements, including holding a valid FAA Part 107 Small UAS Pilot Certificate.  See Appendix D for further information regarding RPIC responsibilities.
LBNL Visual Observers (VO)	The VO has the responsibility to advise the RPIC of eminent hazards to flight. The VO must be able to see the UAS with vision that is unaided by any device other than corrective lenses throughout the entire flight.
LBNL Maintenance Technician (MT)	Repairs and modifies sUAS and ground control station and software. Attaches and removes payloads to UAS as and if needed. Attests to UAS airworthiness, including weight and balance for the duration of each flight, after payload installation or removal, repair, replacement, maintenance, or modification. Records maintenance and/or modifications in the UAS maintenance log. Note: At LBNL RPICs, PIs, or VOs are typically also qualified as MTs and thus a separate individual is generally not needed to function as an MT.

48.4 Definitions

Term	Definition
440.2C Public Aircraft Operations Declaration	An official LBNL letter required by DOE Order 440.2C that declares that LBNL operates its drones as a public entity. See Appendix N.
Above Ground Level (AGL)	The term used in aviation to describe the altitude relative to the ground (including bodies of water).
Accident (UAS related, includes mishaps)	An incident that injures any person or damages any property other than the small unmanned aircraft. See Appendix J. for accident reporting thresholds.
Adversary countries	In reference to Executive Order 13981 of January 18, 2021, “Protecting the United States From Certain Unmanned Aircraft Systems.” The order defines the following adversary countries: “Democratic People’s Republic of Korea, the Islamic Republic of Iran, the People’s Republic of China, the Russian Federation, or, as determined by the Secretary of Commerce, any other foreign nation, foreign area, or foreign non-government entity engaging in long-term patterns or serious instances of conduct significantly adverse to the national or economic security of the United States.”
Air Route Traffic Control Center (ARTCC)	An FAA facility responsible for tracking and routing air traffic in a specific area of the National Airspace. Currently there are 23 ARTCC’s in the U.S. including those for Alaska and Hawaii.
Aircraft	Any device used or intended to be used for flight in the air. It may be manned (e.g., passenger aircraft) or unmanned (e.g., drone or balloon). The term encompasses several types, most commonly (for the purposes of this chapter): * Small unmanned aircraft systems (drones) * Balloons * Kites Note: LBNL does not operate, maintain or host manned aircraft of any type or drones greater than 55 lbs. LBNL staff using manned aircraft for any purpose must do so via Commercial Aviation Services (CAS).
Associate Laboratory Director (ALD) for Environment, Safety and Health (ESH)	The senior LBNL manager reporting to the Laboratory Director and responsible for safe aviation operations at LBNL.
Aviation Mission Request (AMR)	Form attached to this subject area requiring the minimum information to be submitted to the Aviation Point of Contact (APOC) prior to initiating planning for aviation missions.
Aviation Point of Contact (LBNL APOC)	The LBNL Aviation Safety Program Subject Matter Expert (SME). The APOC may designate specific tasks to a designee. See also Director, Office of Aviation Management, Senior Aviation Management Official (SAMO), Aviation Safety Manager (AvM, ASM) and Aviation Safety Officer (ASO)
Director, Aviation Management. Designated as the Senior Aviation Management Official (SAMO)	The DOE Responsible Person for Aviation Safety across all of DOE and NNSA
Aviation Manager (AvM)/Aviation Safety Manager (ASM)	The DOE Responsible Person for Aviation Safety in the DOE Office of Science
Aviation-related activities	Any activity that could impact aviation safety for conduct of LBNL research or non-research flights, even if not directly involved with actual flights.
Aviation Safety Officer (ASO)	The DOE site office representative responsible for oversight of the Aviation Safety Program.
Aviation Safety Plan (ASP)	A formal document that comprehensively describes a research or non-research project involving manned or unmanned aircraft (see “Aircraft”). The document is developed by the LBNL Principal Investigator, Field Site Manager or Designee (also referred to as “Requestor”).
Balloon	A balloon is a lighter-than-air aircraft that is not engine driven, and that sustains flight through the use of either gas buoyancy or an airborne heater. Balloons may be free-flying or tethered (moored). See definitions for unmanned free balloon and moored balloon.
Certificate of Waiver or Authorization (COA)	An authorization issued by the FAA to a public operator for a specific unmanned aircraft activity. The Pilot in Command, Visual Observer, and all crew members are required to be familiar and comply with the stipulations in the COA.
Change management	The process of tracking changes in LBNL documents. For this policy change management focuses on Aviation Safety Plans and WPC documents.
Chartered aircraft	Provided by the Operator on demand, for carrying in air commerce any person or property for compensation.
Commercial Aviation Services (CAS)	CAS includes all contractual arrangements for: * Leased aircraft; * Aircraft chartered or rented for exclusive or non-exclusive use; * Full services (i.e., aircraft maintenance providers, aircraft, and related aviation services for exclusive use) contracted for or obtained through an inter-service support agreement (ISSA), regardless of the length of the contract or agreement; or * Aviation services (i.e., services but not aircraft) obtained by commercial contract or ISSA, except those services acquired to support a Federal aircraft. * Include all aviation operations involving commercial, government, or private entity aircraft that are funded by LBNL via contractual agreement or that arise from a collaborative arrangement between LBNL and other entities. Note: LBNL does not own, operate, maintain or host manned aircraft. CAS does not apply to use of scheduled (commercial) airlines. The list of DOE accepted operators for CAS is available here: DOE Accepted Operators List
Control Station	The electronic device or interface used by the operator to control the flight of a small unmanned aircraft.
Contractor Requirements Document (CRD)	DOE document that specifies aviation requirements from DOE Order 440.2C that prime contractors must implement.
Division Manager (LBNL)	Person responsible for management of a Division at LBNL. Examples include Climate & Ecosystem Sciences Division and Nuclear Science Division.
DIvision Safety Coordinator (LBNL)	Person responsible for Integrated Safety Management (ISM) within a Division at LBNL.
DOE Accepted Operators List	A list of providers of commercial aviation services approved by DOE-OAM. See: https://powerpedia.energy.gov/wiki/Commercial_Aviation_Services_Accepted_Operators_List
DOE Aviation Management (DOE-OAM or, formerly DOE Office of Aviation Management, DOE-OAM)	U.S. Department of Energy Headquarters Organization responsible for ensuring that DOE aviation activities are safe and effective.
DOE Order 440.2C	DOE Order that establishes a policy framework that will ensure safety, efficiency and effectiveness of government or contractor aviation operations. See: DOE O 440.2C Chg 2 (LtdChg), Aviation Management and Safety
DOE-use aircraft	Any aircraft owned by DOE, under DOE’s operational control, or engaged exclusively for use by DOE or a covered contractor for DOE purposes.
Drone	The term “drone” is a general term for a powered unmanned aircraft. Drones require associated elements (including communication links and the components that control the unmanned aircraft) that are needed for the remote pilot in command to operate safely and efficiently in the national airspace system. Sometimes referred to as “unmanned aircraft systems” (UAS) or, sUAS for small (<55 lbs) unmanned aircraft system).
Environment, Health, and Safety Division Liaison	Person within a Division with the responsibility of coordinating with the Environment, Health, and Safety Division, usually the Division Safety Coordinator.
Experimental equipment	Equipment brought on board an aircraft as a payload for the purpose of conducting research operations. Equipment may be either LBNL designed and built, or built by other agencies for use by LBNL.
Federal Aviation Administration (FAA)	The division of the Department of Transportation that inspects and rates civilian aircraft and pilots, enforces the rules of air safety, and installs and maintains air-navigation and traffic-control facilities. Unmanned aircraft systems are regulated under 14 CFR Part 107.
Federal Aviation Administration (FAA) 14 CFR Part 107	FAA regulation for unmanned aircraft systems.
Federal Aviation Administration (FAA) 14 CFR Part 135	Federal Regulations governing the operations of Commercial Airlines in the U.S. (Link provides a list of commercial operators permitted by the FAA.
Federal Aviation Interactive Reporting System (FAIRS)	A management information system operated by the General Services Administration (GSA) to collect, maintain, analyze, and report information on Federal aircraft inventories and cost/usage of Federal aircraft and Commercial Aviation Services (CAS) aircraft and related aviation services. Executive agencies of the United States Government must report to FAIRS if they own, bail, borrow, loan, lease, rent, charter, contract for, or otherwise obtain Government aircraft.
Flight operation	Any process that results in an object or objects overcoming gravity to be suspended in the atmosphere whether tethered or untethered.
Government-owned aircraft	Aircraft purchased by the government for use by the Laboratory. This is typically a small unmanned aircraft system (drone).
Heliport	An identified area which is a site for helicopter landing and takeoff.
Integrated Safety Management (ISM)	Integrated Safety Management is planning and documentation that guides environment, safety, and health policies and practices at the division level at LBNL. ISM provides guiding principles and core functions specific to environment, safety and health policies within each division.
Kite	A framework, covered with paper, cloth, metal, or other material, intended to be flown at the end of a rope or cable, and having as its only support the force of the wind moving past its surfaces. A kite may be tethered (moored) or free-flying. Free-flying kites are not allowed for LBNL research activities.
Leased aircraft	Aircraft provided by the Operator for exclusive use of the Laboratory.
Lessons Learned	Identification and documentation of information regarding the cause of accidents, mishaps or near misses.
Lighting and marking requirements	FAA requirements for lighting and marking of unmanned free balloons and drones.
Line management (LBNL)	Managers and management structure responsible for day to day activities of employees at LBNL. See: https://www.lbl.gov/laboratory-organization-chart/.
Low Altitude Authorization and Notification Capability (LAANC)	LAANC is a collaboration between FAA and Industry. It directly supports small unmanned aircraft system (UAS) integration into the airspace. Key features of LAANC include (1) providing UAS pilots with access to controlled airspace at or below 400 feet, (2) awareness of where pilots can and cannot fly and (3) providing air traffic professionals with visibility into where and when UAS are operating.
Manned aircraft	Aircraft that accommodate pilot and passenger(s). This includes both helicopters, fixed wing aircraft. Note: LBNL does not operate, maintain or host manned aircraft on site.
Monthly Report	A mandatory report on drone flights that is due to the Director of DOE Aviation Management no later than the 10th day of each month.
Moored balloon	A non-powered, unmanned, lighter-than-air device that is tethered to the ground.
National Airspace System (NAS), also known as public airspace.	The National Airspace System is the airspace, navigation facilities and airports of the United States along with their associated information, services, rules, regulations, policies, procedures, personnel and equipment. It includes components shared jointly with the military. https://en.wikipedia.org/wiki/National_Airspace_System
National Airspace System Classifications (e.g. B, C, D, E, or G)	3-dimensional geographic designations of the National Airspace by the FAA that govern aircraft requirements and activities. In the U.S., airspace consists of classes A, B, C, D, E, and G. The NAS includes both controlled and uncontrolled airspace. LBNL drones are only allowed to fly in Class G airspace defined as: Class G airspace is uncontrolled airspace which extends from the surface to either 700 or 1,200 ft. AGL depending on the floor of the overlying Class E, or to the floor of Class A where there is no overlying Class E. In the vicinity of an uncontrolled airport, the CTAF for that airport is used for radio communication among pilots. In remote areas other frequencies such as MULTICOM are used. No towers or in-flight control services are provided although communications may be established with flight service stations which are not part of the NAS. and advisory service may be available from Air Route Traffic Control Centers. Definitions for all of the airspace classifications are available at https://en.wikipedia.org/wiki/National_Airspace_System
Non-LBNL personnel	Any person who is not an LBNL employee or affiliate.
Non-research flight operations (or, non-research activities)	Non-research operations are undertaken for the purposes of photography, transport, and surveillance. This kind of operation does not involve carrying experimental or data collection equipment on board. See also Research Flight Operations.
Notice Requirements	Any FAA requirement for notification to ATC before, during or after flight operations. Includes Notice to Airmen and also specific DOE notice requirements for balloon flights.
Notice to Airmen (NOTAM)	A notice filed with an aviation authority to alert aircraft pilots of potential hazards along a flight route or at a location that could affect the safety of the flight. A NOTAM is filed with an aviation authority to alert aircraft pilots of any hazards en route or at a specific location. The authority in turn provides a means of disseminating relevant NOTAMs to pilots. See Appendix G.
Part 61 Private Pilot Certificate (Remote rating)	A remote pilot rating assigned to individuals with a private pilot certificate after completion of requirements for said rating.
Payload	Equipment or devices attached to an aircraft that perform a desired function during flight. The payload weight is a critical parameter limited by the lift capacity of the aircraft.
Payload cut-down systems	A system designed to release a balloon payload upon remote command from the operator or in an automated fashion based on specific flight parameters.
Person Manipulating the Controls	A person other than the remote pilot in command (RPIC) who is controlling the flight of a UAS under the supervision of the RPIC.
Pilot in Command (PIC)	The individual who: Has final authority and responsibility for the operation and safety of the flight; Has been designated as pilot in command before or during the flight; and Holds the appropriate category, class, and type rating, as appropriate, for the conduct of the flight. Same as Remote Pilot in Command (RPIC). For the purposes of this document, PIC and RPIC are used interchangeably, but RPIC is preferred for clarity since LBNL does not operate manned aircraft. For small unmanned aircraft systems, the RPIC is required to hold FAA Part 107 certification.
Pre-flight checklist	A list of items to be checked off prior to flight, and, prior to and after landing.
Principal Investigator (PI)	Person responsible for a specific research project.
Privately owned aircraft	Aircraft owned and/or operated by LBNL employees or affiliates. Note: Aircraft owned or piloted by Laboratory employees (manned or unmanned) are not authorized for use on Laboratory business.
Procurement Department (LBNL)	Organization at LBNL that processes all purchases of goods and services for the lab.
Rapid deflation device	A device that allows the buoyant gas in a balloon to be rapidly released into the atmosphere upon remote command or automatically based on specified parameters. Triggering of a rapid deflation device results in irreversible termination of a balloon flight.
Registration number	A unique identifying number assigned by the FAA to an aircraft. The registration number must be displayed per specific requirements for each aircraft type.
Remote Identification	Ability of a drone in flight to provide identification and location information that can be received by other parties.
Remote Pilot Certification (Part 107)	FAA certification of individuals allowing them to legally fly drones under Part 107 or as a remote pilot of a public aircraft. For small unmanned aircraft systems, the RPIC is required to hold FAA Part 107 certification.
Remote Pilot in Command (RPIC or PIC)	Same as Pilot in Command (PIC). For the purposes of this document, PIC and RPIC are used interchangeably, but RPIC is preferred for clarity since LBNL does not operate manned aircraft.
Research flight operations (or Research Operations, research activities)	Research flight operations involve the carrying of LBNL or other experimental equipment on board an aircraft for the purpose of conducting experimentation and/or data collection. See also non-research flight operations.
Responsible Person (RP)	For manned aircraft operations, the person who is directly responsible for the experiment/research on or during the flight. This could be the Principal Investigator (PI) in charge of the experimental apparatus.
Richmond Field Station (University of California, Berkeley, RFS)	A University of California facility located on the San Francisco Bay seven miles northwest of the central campus of University of California, Berkeley. The Richmond Field Station (RFS) is an off-site academic facility used primarily for large-scale engineering research since 1950. The 170-acre property consists of 100-acres of uplands with the remainder being marsh or bay lands. See: https://rfs.berkeley.edu. RFS is available to LBNL pilots and crew for practice and research drone flights. In order to use the facility, it must be reserved using the following link to schedule requests: https://ucbrfs.dronefms.net/. Contact Justin Cocke: justincocke@berkeley.edu, 510-220-2712, for questions regarding the use of RFS for drone flights. See Appendix T for additional information
Risk Assessment (or Hazard Risk Analysis)	A systematic process for assessing the risks associated with flight operations. See Appendix B.
Scheduled commercial airlines	Corporate entities that provide passenger transport on a regularly scheduled basis. Such entities are regulated by the Federal Aviation Administration (FAA) under 14 CFR Part 135 .
Small Unmanned Aircraft Systems (UAS)	As defined by the FAA, and for the purposes of this Policy, a UAS is a drone weighing less than 55 pounds, including everything that is onboard or otherwise attached to the aircraft, and that can be flown without the possibility of direct human intervention from within or on the aircraft.
Standard Pressure Altitude	Pressure altitude is the height above a standard datum plane (SDP), which is a theoretical level where the weight of the atmosphere is 29.92 “Hg (1,013.2 mb) as measured by a barometer. An altimeter is essentially a sensitive barometer calibrated to indicate altitude in the standard atmosphere. From: https://www.faa.gov/regulations_policies/handbooks_manuals/aviation/phak/media/06_phak_ch4.pdf
UAS Notification to DOE HQ OAM Senior Aviation Manager (Form 19)	A notification (form) required by DOE HQ OAM prior planning and conducting UAS flights. See Appendix F.
Unmanned aircraft	An airborne platform, including drones, balloons (free or tethered) and kites, that is not equipped or designed to carry pilot(s) or passengers and operated without the possibility of direct human intervention from within or on the aircraft. This is a general term that includes all types of unmanned aircraft systems, including those under 55 pounds.
Unmanned Aircraft System (UAS)	The term “unmanned aircraft system” means an unmanned aircraft and associated elements (including communication links and the components that control the unmanned aircraft) that are required for the pilot in command to operate safely and efficiently in the national airspace system. Typically referred to as “small unmanned aircraft systems” (sUAS, less than 55 lbs) or, simply, “drones”.
Unmanned Free Balloon	A non-powered, unmanned, lighter-than-air device that is allowed to freely ascend through the atmosphere without directional guidance. Such devices are classified according to the payload and the number of packages they carry.
Visual Flight Rules (VFR)	A set of FAA regulations under which a pilot operates an aircraft in weather conditions generally clear enough to allow the pilot to see where the aircraft is going.
Visual Line of Sight (VLOS)	Requirement to maintain unaided visual observation of a drone during flight.
Work Planning & Control (WPC)	LBNL process for assessing and mitigating project safety risks.
WPC Activity	An LBNL work scope that is the subject of the work planning & control process and documentation of same.
WPC Activity Lead	LBNL employee assigned to develop and manage work planning and control process and documentation.

48.5 Operational Requirements

48.5.1 Standards of Performance

Standards of performance are governed by the following regulatory agencies:

1. Department of Energy Order 440.2C
2. Federal Aviation Administration (FAA) Title 14 CFR Part 107
3. Federal Aviation Administration (FAA) Title 14 CFR Part 101

LBNL aviation safety requirements will meet or exceed the standards of performance governed by these regulatory agencies. Irrespective of the governing regulations or LBNL requirements, managers or their designees are required to analyze work for hazards, authorize work to proceed, and ensure that work is performed within established controls.

Research and non-research work conducted by LBNL employees that involves the operation of UAS must be comprehensively addressed in an ASP, which includes the requirement for a risk assessment.

The use of a CAS for personnel or equipment transport is also governed by this Policy. This Policy does not apply to the use of scheduled (commercial) airlines. The use of CAS must be discussed in the WPC Activity.

With the exception of using scheduled commercial airlines for travel to and from research locations, all operations involving aircraft, manned and unmanned, must be authorized via WPC. An up-to-date ASP and current supplementary documentation must be included as attachments in each WPC Activity involving UAS.

Consistent with Integrated Safety Management (ISM), LBNL employees shall, in addition to defining the work they plan to perform, identify, evaluate, and control hazards in order to ensure aircraft operations are conducted safely and in a manner that protects personnel, property, the environment, and the public. In UAS operations, the feedback and improvement portion of the ISM process is carried out via a post-flight debriefing. Opportunities for improvement should be incorporated into future flight operations and shared with the LBNL aviation community as well as through other means of widespread communication to other DOE sites, including but not limited to Lessons Learned. ASPs may be revised at any time and those revisions MUST be communicated to flight crews. When an ASP is revised, the owner must notify their Division Safety Coordinator and the APOC, who must concur with the revisions.

48.5.2 Research and Non-Research Aviation Activities

There are two broad categories of LBNL aviation-related activities. “Aviation-related activities,” per se, is a general phrase that may involve any type of aircraft. It is divided into two categories:

1. Research
2. Non-research

Both categories of aviation-related activities may involve remotely controlled and/or operated aircraft, or LBNL personnel on board an aircraft during flight.

Note: balloons and kites, which are sometimes deployed as research operation platforms, are considered to be UAS. Under no circumstance are LBNL employees permitted to conduct research as passengers in a manned balloon.

All aviation-related activities must be reviewed by the APOC and approved by line management in a WPC Activity. Those involving UAS must also be vetted with the ASO and reviewed by the OAM.

48.5.3 Aviation Safety Plans

With the exception of using scheduled commercial airlines, every aviation-related activity involving UAS, balloons or kites (both research and non-research, as applicable) must be described in a comprehensive Aviation Safety Plan (ASP) and submitted to the APOC for review and approval.

Note: unless it is included as an element of operating a UAS, the use of CAS does not require an ASP; however, it must be described in a WPC Activity. Any supporting documentation should also be submitted to the APOC during the WPC Activity approval process.

Since the DOE is involved in the review and approval of aviation missions, submission of an ASP should be made as early as possible in the planning stages of a mission. It is recommended that the ASP and supporting documentation be submitted to the DSC and APOC 60 days prior to the anticipated mission date. In general, once an ASP is presented to the DOE for initial review, subsequent revisions to the ASP are reviewed by the APOC and, as warranted, the ASO.

See Appendix E for an example Aviation Safety Plan.

48.5.4 Project Review and Approval Process

All experimental equipment provided as a UAS payload by LBNL must be reviewed for safety hazards prior to installation on an aircraft (manned or unmanned). The Remote Pilot in Command (RPIC) who will operate or supervise the operation of a UAS (including balloons and kites) carrying a payload has the final authority as to what type of equipment can be carried on the aircraft.

Aviation-related projects require advance planning, which includes the following steps:

1. Determine whether the use of manned or unmanned aircraft is necessary for the proposed project.
2. Determine the type of aircraft needed to meet project goals, including the use of CAS and complete the Aviation Mission Request (AMR) form.
3. Contact the APOC for guidance, including the procedures and timing for procuring sUAS and approvals.
   
   Note: It is conceivable that a research project could require the use of a CAS not on the DOE Accepted Operator List. In such cases, when a CAS is not listed, LBNL is required to request a review of the operator by the DOE prior to using the service. This is a complex process and requesting an “off list” CAS is discouraged. In any event, LBNL personnel may not use operators who are not on the DOE Accepted Operator List.
   
   
4. Develop an ASP for the project, including required supporting documentation.
5. Vet the ASP with the DSC and the APOC. Following review and approval, the APOC will forward the ASP and other required documentation to the ASO, who will review and forward to the OAM for final review and comment.
6. Once the ASP and other required documentation have been approved, develop a WPC Activity.
7. Categorize the project as either research or non-research. For reference:
   1. Research Operations
      1. Broadly described as involving the transport of personnel or the use of DOE-owned or other experimental equipment on board an aircraft for research purposes. This includes, as applicable:
         1. UAS less than 55 pounds
         2. Unmanned free balloons
         3. Moored balloons or kites
         4. CAS (transporting passengers and/or equipment)
            
            Note: the use of manned balloons for research operations is not permitted under any circumstance.
            
            
   2. Non-Research Operations
      1. Broadly described as projects undertaken for the purposes of photography, videography, or surveillance, and which do not involve transporting LBNL personnel or experimental equipment onboard an aircraft.
         
         Note: non-research flight operations do not generally involve the use of unmanned balloons and kites, and are NOT allowed to involve the use of manned balloons. Under unusual circumstances, non-research operations may require the use of CAS.

48.5.5 Unmanned Aircraft Systems (Drones)

This section applies to staff planning to operate drones less than 55 pounds (including payload) in Class G airspace, typically under the DOE nationwide COA. Operations in other classes of airspace are possible under Part 107 rules, typically requiring FAA approval. Such aircraft and their control systems are typically available commercially.

LBNL personnel may not operate UAS (including payload) greater than 55 pounds.

Refer to Sections 48.1.6 and 48.1.7 for requirements related to unmanned free balloons and moored balloons/kites, respectively.

The steps outlined in the following subsection are required prior to operating drone-type UAS as part of LBNL work.

48.5.5.1 Planning and Obtaining Approval for Flying a small Unmanned Aircraft System (sUAS) or “Drone”

Planning to Fly

The following steps shall be followed when planning a project involving a drone (UAS) locally (e.g., practice flights) or conducting operational flights in the field. Contact the APOC well in advance of planned flight operations when requesting approval. This will help ensure a clear understanding of what is involved in obtaining approval to operate a drone during the course and scope of conducting LBNL business.

1. Provide the following documentation to the APOC with your request to conduct UAS operations per LBNL’s WPC process:
   1. Aviation Mission Request (AMR) Form (typically submitted when initiating contact with the APOC).
   2. The ASP. This is typically developed by the Principle Investigator (PI), RPIC or WPC Activity Lead, reviewed by the APOC and submitted to the ASO, who will forward it to the DOE-OAM. See Appendix E for an example Aviation Safety Plan.
   3. The UAS Notification to DOE-OAM Senior Aviation Manager (Form 19). See Appendix F.
   4. The WPC Activity number. The WPC Description of Work primarily summarizes what is included in the ASP, which resides as an attachment in the Activity.
2. Complete a WPC Activity for review by the DSC, EHS Division Liaison, and APOC. It is recommended that the Activity Lead begin developing the WPC Activity in advance of OAM approval. The APOC can be consulted as needed for guidance regarding the WPC Activity, but will primarily be focused on the content of the ASP.
3. The WPC Activity must include as attachments the following documents, which are also required to be included in the completed ASP:
   1. Drone registration
   2. Drone manufacturer manual (may be via link)
   3. Part 107 Pilot Certification document (for each RPIC)
   4. Current Certificate of Waiver or Authorization (COA), unless conducting flights under Part 107.
   5. UAS Notification to DOE-OAM Senior Aviation Manager
   6. 440.2C Public Aircraft Operations Declaration (Appendix N)

These documents can be readily updated in the ASP that is attached to the WPC Activity. Since some of these documents are routinely revised (e.g., RPIC certificates and COA), it is more efficient to make changes to the ASP document than to continually update the WPC Activity.

4. Provide a certificate of insurance for collaborators on an LBNL project (e.g., non-LBNL personnel) who must fly an LBNL-owned UAS and serve as FAA Part 107 certified RPICs (i.e., not fly under the supervision of an LBNL RPIC). Generally, flying LBNL-owned UAS by non-LBNL employees, even when done so under the supervision of an RPIC, is discouraged but not prohibited. The certificate of insurance for a non-LBNL RPIC who will fly an LBNL-owned UAS must be vetted with the APOC, who will consult with LBNL Risk Management or designee.

1. Vendors and subcontractors are not allowed to fly on LBNL property, irrespective of experience or certification status. In extreme cases requiring the expertise of a vendor, the project will be vetted in the same manner as it would be for an LBNL employee. Contact the APOC for guidance.
2. Non-LBNL personnel are not permitted to fly LBNL-owned sUAS unless expressly authorized in the ASP and WPC Activity. When this is the case, they must be directly supervised by the LBNL RPIC.
3. LBNL personnel who fly a UAS as a participant on a host project must hold a 107 Pilot Certification. In contrast to LBNL projects, where an uncertified LBNL pilot may fly under the direct supervision of an FAA certified RPIC, an uncertified LBNL person may not fly under the direct supervision of a certified host RPIC. Under the host project condition, an ASP is not required, but any work done as a participant on a host project must be covered in an approved WPC Activity.
4. Night flights are allowed for both COA flights and Part 107 flights. However, such flights must be approved by APOC as part of the WPC and the ASP. In addition, all such flights must meet current requirements of Part 107 or the COA, whichever is applicable.

Purchasing a Drone

Follow the rules when purchasing an UAS. Drones and components (UAS) are considered restricted items. The LBNL Procurement Department has established a process that assures drone and related components are approved prior to executing the purchase. Purchasing a drone and components (including the primary platform) requires advance review and approval by the APOC (or designee). This process is regulated by LBNL Procurement Policy.

Prospective RPICs are not permitted to purchase a UAS outside LBNL’s procurement process. If it is deemed necessary to purchase a drone in advance of securing OAM and WPC authorizations, secure final division and APOC (or designee) approvals.

There are or may be restrictions on the purchase of UAS that are or may be manufactured in adversary countries. Designation of “adversary” status is subject to change. Contact the APOC prior to initiating the purchase of a drone.

The possession of a drone does not automatically permit flying. RPICs must possess an FAA Part 107 Remote Pilot Certificate and undergo complete vetting prior to initiating flight operations. Vetting includes development of both an approved ASP and WPC Activity. Only after vetting and full approval is the RPIC allowed to begin practice or mission flight operations, which must include a Visual Observer (VO). The Remote Pilot Certificate must be renewed every 2 years as described in Appendix U.

48.5.5.2. Operating a Drone

General Requirements: The Basics

LBNL drone operations occur in “public airspace.” The DOE holds and periodically renews a COA for this purpose, and RPICs and crew members are required to be knowledgeable regarding its content and intent. This Policy provides the latest version of the DOE COA. See Appendix M. Typically it is advantageous for LBNL staff meeting the requirements of this policy to fly under the DOE COA. For example, the COA allows for flights up to 1200 feet AGL in Class G airspace. However, staff may have needs to fly in other airspace classes, in which case staff may also fly under FAA’s Part 107 rules (limited to 400 feet AGL). Flights under FAA Part 017 are reported differently that under DOE’s nationwide COA (see Item N under “Specific Requirements” below)

LBNL employees are required to carefully plan flight operations, including practice flights, per the ASP and WPC Activity. Daily assessment of hazards and other risks must be evaluated prior to each flight. When material changes in the flying environment are anticipated or encountered, it is the responsibility of the RPIC to account for those changes and revise the flight plans, including ceasing flight operation if necessary. The RPIC is responsible for briefing flight crews, including the VO, prior to commencing flight operations and for logging and reporting all flights (Appendix C).

The UC Richmond Field Station (RFS) is available to LBNL pilots and crew for practice and research flights. In order to use the facility, it must be reserved using the following link to schedule requests – https://ucbrfs.dronefms.net/.

Contact Justin Cocke – justincocke@berkeley.edu at 510-220-2712 for questions regarding the use of RFS for drone flights. See Appendix T for additional information.

Change management is a critical element of flight operations. While the Hazard Risk Analysis included in the ASP addresses a range of hazards and consequences, it cannot account for changes in the immediate operating environment. As a guideline, when the Hazard Risk Assessment no longer reflects the likelihood and consequence of issues associated with the project, flight operations must stop and be reevaluated. It is up to the RPIC to modify the Hazard Risk Assessment section of the ASP to reflect changes in project risks that were not initially anticipated.

Specific Requirements

RPICs, VOs and crews are responsible for remaining current with applicable DOE and FAA regulations and ensuring compliance during flight operations, as follows (see also Appendix D):

1. RPICs must ensure flights are compliant with the conditions of the DOE COA and related requirements (in addition to height and airspace limitations) or compliant with 14 CFR 107 in addition to best flying practices. See Appendix L for a concise summary of the DOE COA and Appendix M for the current DOE COA.
2. Per the DOE COA, RPICs must remain in Class G Airspace during flight operations. Flights in other than Class G airspace are possible, but require that the RPIC fly under Part 107 rules.
3. During UAS activities, RPICs must carry documentation of completion of either the FAA Remote Pilot Certificate with a small UAS rating or the Part 61 Private Pilot Certificate. RPICs must also provide a photo ID to support their Remote Pilot Certificate.
4. RPICs must carry the ASP, which contains all other relevant documents such as aircraft registration and the COA.
5. LBNL flight operations are limited to flying no higher than 400 feet above ground level (AGL) in spite of the fact that the COA allows flight up to 1200 feet AGL. Requests for exceptions are routinely granted for flights under the COA in Class G airspace only, but require specific APOC approval. Once approval is obtained and when flying under Part 107, LAANC may be invoked to fly at AGL greater than 400 feet (see Appendix O).
6. LBNL flight operations are typically approved for daylight hours. Both the COA and Part 107 rules permit night flights, so night flight operations can be approved if included in the WPC and the ASP.
7. LBNL flight operations are not permitted over people. Requests for exceptions require APOC approval and must meet the current requirements under Part 107.
8. LBNL flight operations are not permitted over moving vehicles. Requests for exceptions require APOC approval and must meet the current requirements under Part 107.
9. Drones must be maintained in safe operating condition and pilots must confirm this prior to each flight.
10. RPIC and crew must complete a pre-flight checklist. See Appendix H for a model pre-flight checklist. The checklist used must effectively cover the items in the model pre-flight checklist.
11. The aircraft registration number must be clearly visible on the outside of the drone.
12. Beginning approximately September 16, 2023, all UAS will be required to be equipped with remote identification. See Appendix R.
13. Drones must be operated within visual line of sight (VLOS) and must yield right of way to other aircraft (manned or unmanned).
14. The RPIC or designee must provide a monthly report, including maintenance and number of hours flown (including zero), to the APOC or designee. A standardized spreadsheet used by DOE-OAM is provided to all RPICs for monthly reporting.
    1. The APOC (or delegate) submits the monthly report of LBNL drone activities conducted under the DOE Nationwide COA to the Director of DOE-OAM and copies the ASO. The APOC retains a record of monthly reports.
    2. For operations under 14 CFR 107, the cognizant DOE Aviation Safety Manager (or delegate) reports ongoing Part 107 operations to MA-30 via an email detailing Part 107 operations as they occur.
15. All mishaps/accidents must be reported to the APOC within 12 hours to determine if the FAA needs to be notified. This is outlined in the DOE COA. Depending on the type of event, the FAA must be notified within 10 days. The APOC will notify the ASO, who will notify DOE-OAM. See Appendix J.
16. RPICs must maintain currency with each drone model they fly by conducting at least 3 takeoffs and landings every 90 day.
17. If currency is not maintained, it can be regained by conducting practice 3 takeoffs and landing prior to conducting mission flights. Such flights must be documented in the RPICs log book and ideally are observed by an LBNL pilot who has maintained his or her currency.
18. The RPIC or designee must file a NOTAMs when flying under the DOE COA (see Appendix G). When flying under Part 107, filing an “Unmanned Aircraft Operating area (UAO) at www.1800wxbrief.com typically will suffice.
19. Respond to suspicious UAS or other aviation activity (Appendix K).
20. Follow guidance in Appendix S when interacting with the public, particularly if individuals appear to be hostile to UAS operations.
21. Report UAS inventory and costs to the APOC for FAIRS reporting, if required. Federally owned UAS with value less than $500,000.00 are exempt from FAIRS reporting. Non-Federally owned UAS are subject to FAIRS reporting. It is recommended that all UAS be purchased as Federally owned property. If project circumstances require non-federal ownership of a drone, FAIRS reporting costs may be charged to the project.

48.5.5.3 Data Management

All data from sUAS flights are downloaded, backed up and processed in accordance with project goals, objectives and requirements, and LBNL Data Management Policy (https://commons.lbl.gov/display/itdivision/Data+Management).

48.5.5.4 Summary of Work Processes for UAS^1,2

48.5.6 Unmanned Free Balloons

48.5.6.1 Applicability

Unmanned free balloons penetrate National Air Space and therefore may pose a hazard to military and civilian aviation operations. Under no circumstance shall an LBNL employee release an unmanned balloon during the course of conducting research without prior formal authorization and making required notifications.

Unmanned free balloon operators at LBNL must include balloon flights in their WPC Activity documentation and the APOC must be included in the review and approval process. The WPC Activity must document that the balloon operator clearly understands free balloon operational requirements as specified by the FAA, and demonstrates the ability to comply with those requirements.

For further information, see FAA regulations for unmanned free balloons.

48.5.6.2 Operating Limitations

Unmanned free balloons may not be operated under the following conditions:

1. Unless otherwise authorized by ATC, below 2,000 feet above ground level (AGL) within the lateral boundaries of the surface areas of Class B, Class C, Class D, or Class E airspace designated for an airport;
2. At any altitude where there are clouds or obscuring phenomena of more than five-tenths coverage;
3. At any altitude below 60,000 feet standard pressure altitude where the horizontal visibility is less than five miles;
4. During the first 1,000 feet of ascent, over a congested area of a city, town, or settlement or an open-air assembly of persons not associated with the operation; or
5. In such a manner that impact of the balloon, or part thereof including its payload, with the surface creates a hazard to persons or property not associated with the operation.

48.5.6.3 Equipment and Marking Requirements

No unmanned free balloon may be operated unless the following conditions are met:

1. It is equipped with at least two payload cut-down systems or devices that operate independently of each other;
2. At least two methods, systems, devices, or combinations thereof, that function independently of each other, are employed for terminating the flight of the balloon envelope; and
3. The balloon envelope is equipped with a radar reflective device(s) or material that will present an echo to surface radar operating in the 200 MHz to 2700 MHz frequency range.

The operator shall activate the appropriate flight termination devices required by the paragraphs above when weather conditions are less than those prescribed for operation as outlined below, or if a malfunction or any other reason makes the further operation hazardous to other air traffic or to persons and property on the surface.

48.5.6.4 Additional Restrictions

1. Operation of an unmanned free balloon below 60,000 feet standard pressure altitude between sunset and sunrise (as corrected to the altitude of operation) is prohibited unless the balloon and its attachments and payload, whether or not they become separated during the operation, are equipped with lights that are visible for at least 5 miles and have a flash frequency of at least 40, and not more than 100 cycles per minute.
2. Operation of an unmanned free balloon that is equipped with a trailing antenna that requires an impact force of more than 50 pounds to break it at any point is prohibited unless the antenna has colored pennants or streamers that are attached at not more than 50 foot intervals and that are visible for at least one mile.
3. No person may operate between sunrise and sunset, an unmanned free balloon that is equipped with a suspension device (other than a highly conspicuously colored open parachute) more than 50 feet long, unless the suspension device is colored in alternate bands of high conspicuity colors or has colored pennants or streamers attached which are visible for at least one mile.

48.5.6.5 Notice Requirements

The following information outlines required notifications.

1. Pre-launch notice

Except as provided in paragraph B of this section, LBNL personnel not may operate an unmanned free balloon unless, within 6 to 24 hours before beginning the operation, the following information is provided to the FAA Air Traffic Control Center (ATC) facility that is nearest to the place of intended operation:

1. The balloon identification.
2. The estimated date and time of launching, amended as necessary to remain within plus or minus 30 minutes.
3. The location of the launching site.
4. The cruising altitude.
5. The forecast trajectory and estimated time to cruising altitude or 60,000 feet standard pressure altitude, whichever is lower.
6. The length and diameter of the balloon, length of the suspension device, weight of the payload, and length of the trailing antenna.
7. The duration of flight.
8. The forecast time and location of impact with the surface of the earth.
9. For solar or cosmic disturbance investigations involving a critical time element, the information in paragraph (a) of this section shall be given within 30 minutes to 24 hours before beginning the operation.
10. Cancellation notice
    1. If the operation is canceled, the person who intended to conduct the operation shall immediately notify the nearest FAA ATC facility.
11. Launch notice
    1. Each person operating an unmanned free balloon shall notify the nearest FAA or military ATC facility of the launch time immediately after the balloon is launched.
12. Balloon position reports

1. Each person operating an unmanned free balloon shall:
   1. Unless ATC requires otherwise, monitor the course of the balloon and record its position at least every two hours; and
   2. Forward any balloon position reports requested by ATC.
2. One hour before beginning descent, each person operating an unmanned free balloon shall forward to the nearest FAA ATC facility the following information regarding the balloon:
   1. The current geographical position.
   2. The altitude.
   3. The forecast time of penetration of 60,000 feet standard pressure altitude (if applicable).
   4. The forecast trajectory for the balance of the flight.
   5. The forecast time and location of impact with the surface of the earth.
3. If a balloon position report is not recorded for any two-hour period of flight, the person operating an unmanned free balloon shall immediately notify the nearest FAA ATC facility. The notice shall include the last recorded position and any revision of the forecast trajectory. The nearest FAA ATC facility shall be notified immediately when tracking of the balloon is re-established.
4. Each person operating an unmanned free balloon shall notify the nearest FAA ATC facility when the operation is ended.

48.5.6.6 Data Management

All data from unmanned free balloon flights must be downloaded, backed up and processed in accordance with project goals, objectives and requirements, and LBNL Data Management Policy (https://commons.lbl.gov/display/itdivision/Data+Management).

48.5.6.7 Summary of Work Processes for Unmanned Free Balloons^{1, 2}

48.5.7 Moored Balloons and Kites

Moored balloons and kites are rarely used at LBNL. However, due to the changing nature of research, there may be occasions where they are needed. Moored balloon operators must include such flights in their WPC documentation, including the APOC, in the review and approval process. The WPC must document that the operator clearly understands moored balloon and kite operational requirements specified by the FAA and demonstrate ability to comply with those requirements.

This section addresses the operation of moored balloons and kites per FAA requirements.

For further information, see FAA regulations for moored balloons and kites.

48.5.7.1 Applicability

This subpart applies to the operation of moored balloons and kites. However, a person operating a moored balloon or kite within a restricted area must comply only with §101.19 and with additional limitations imposed by the using or controlling agency, as appropriate.

48.5.7.2 Operating Limitations

1. Except as provided in paragraph (b) of this section, no person may operate a moored balloon or kite:
   1. Less than 500 feet from the base of any cloud;
   2. More than 500 feet above the surface of the earth;
   3. From an area where the ground visibility is less than three miles; or
   4. Within five miles of the boundary of any airport.
2. Paragraph (a) of this section does not apply to the operation of a balloon or kite below the top of any structure and within 250 feet of it, if that shielded operation does not obscure any lighting on the structure.

48.5.7.3 Notice Requirements

1. No person may operate an unshielded moored balloon or kite more than 150 feet above the surface of the earth unless, at least 24 hours before beginning the operation, he gives the following information to the FAA ATC facility that is nearest to the place of intended operation:

1. The names and addresses of the owners and operators.
2. The size of the balloon or the size and weight of the kite.
3. The location of the operation.
4. The height above the surface of the earth at which the balloon or kite is to be operated.
5. The date, time, and duration of the operation.

48.5.7.4 Lighting and Marking Requirements

1. No person may operate a moored balloon or kite, between sunset and sunrise unless the balloon or kite, and its mooring lines, are lighted so as to give a visual warning equal to that required for obstructions to air navigation in the FAA publication “Obstruction Marking and Lighting”.
2. No person may operate a moored balloon or kite between sunrise and sunset unless its mooring lines have colored pennants or streamers attached at not more than 50 foot intervals beginning at 150 feet above the surface of the earth and visible for at least one mile.

48.5.7.5 Rapid Deflation Device

1. No person may operate a moored balloon unless it has a device that will automatically and rapidly deflate the balloon if it escapes from its moorings. If the device does not function properly, the operator shall immediately notify the nearest ATC facility of the location and time of the escape and the estimated flight path of the balloon.

48.5.7.6 Data Management

All data from tethered balloon and kite flights must be downloaded, backed up and processed in accordance with project goals, objectives and requirements, and LBNL Data Management Policy (https://commons.lbl.gov/display/itdivision/Data+Management).

48.5.7.7 Summary of work processes for moored balloons and kites ^{1, 2}

48.5.8 Commercial Aviation Services (CAS)

48.5.8.1 Introduction

Per DOE regulations, Commercial Aviation Services (CAS) include all contractual and collaborative arrangements for:

1. Leased aircraft,
2. Aircraft chartered or rented for exclusive or non-exclusive use,
3. Full services (i.e., aircraft maintenance providers, aircraft, and related aviation services for exclusive use) contracted for or obtained through an inter-service support agreement (ISSA), regardless of the length of the contract or agreement, or
4. Aviation services (i.e., services but not aircraft) obtained by commercial contract or ISSA, except those services acquired to support a Federal aircraft.

LBNL does not own, operate, maintain or host manned aircraft. The only requirement applicable to LBNL operations is addressed in Item B above.

This applies to commercial, government, or private entity aircraft that are funded by LBNL via contractual agreement or that arise from a collaborative arrangement between LBNL and other entities.

48.5.8.2 Applicability

This section applies to the utilization of aircraft that are chartered, leased, or government owned and used during the course and scope of LBNL business. It does not apply to the use of scheduled (commercial) airlines.

CAS requirements also do not apply to contractual agreements or collaborative arrangements where the vendor or collaborator supplies data or interpretations, where LBNL data collection equipment is not flown and LBNL employees are not transported. Under those circumstances, LBNL employees have no involvement in flight chartering, planning or execution of data collection during flights.

48.5.8.3 Operating Limitations

DOE Order 440.2C requires confirmation – via vetting with the APOC – that a CAS has been selected from the DOE Accepted Operators List prior to entering into a purchase order to charter aircraft services of any type. This applies to both transport of employees and equipment.

The APOC will consult with the ASO when questions regarding the use of CAS. In particular, when a CAS is not on the Accepted Operators List but its services are desired, a request may be submitted for consideration. Supporting documentation must be created and submitted with the CAS request. The DOE is involved in the review and approval of aviation missions, and any submittal should be made as early as possible in the planning stages of a mission and in no case less than 60 days prior to the anticipated mission date.

Note: a request to use a non-listed commercial aviation services provider must be processed by the LBNL APOC in collaboration with the ASO. The APOC will not proceed unless there are extremely compelling reasons to do so. Every effort should be made to identify a scheduled air carrier or a listed commercial air service.

Commercial air carriers operating under 14 CFR Part 135 are excluded from this requirement. Contact the APOC for assistance in complying with the CAS requirements contained in DOE Order 440.2C.

LBNL does not own or operate a landing field, so its use of CAS operators will be limited to off-site field research situations. The following requirements will apply:

1. Unless otherwise specified, all aviation operations purchased will be conducted during daylight hours and will strictly adhere to, and comply with Federal Aviation Administration (FAA) Visual Flight Rules (VFR) Regulations.
2. Before mission operations commence, the person responsible for the aviation charter-service purchase will obtain the model of the aircraft, name of the aircraft operator and telephone number, name of the pilot in command.
3. LBNL employees may only ride on accepted CAS operator aircraft if previously authorized as “essential” by the division director or deputy.

All CAS operations must be reviewed by the APOC and approved by the Associate Laboratory Director (ALD) for Environment, Safety and Health (ESH) prior to commencing operations.

First Notice of Intent to Use a Non-Scheduled CAS

The research must notify the APOC prior to initiating the authorization process. This is done using the Aviation Mission Request (AMR) Form. This is an initial notification to begin the process, not an authorization to fly or seek approval to use flying service not already on the DOE CAS list.

1. Determine if the use of aircraft is necessary for the conduct of Lawrence Berkeley National Laboratory (LBNL) business. For assistance, contact the APOC.
2. Assign a Responsible Person who ensures that all necessary information is provided to the APOC using the Aviation Mission Request (AMR) Form.
3. Obtain approval to pursue aviation operations from the Division or Area management.
4. Categorize the aviation mission type as either non-research or research.

48.5.8.4 Safety Hazard Review

All experimental equipment provided by LBNL must be reviewed for safety hazards prior to installation on an aircraft. This review should be conducted by the WPC Activity Lead or RPIC, and the APOC. The RPIC is in the best position to determine what type of equipment may be carried on the CAS aircraft, but the CAS pilot has the final authority to determine what will be carried on the CAS aircraft.

48.5.8.5 Collaboration with other entities

LBNL staff commonly collaborate with other entities including, but not limited to, other national laboratories, government agencies, universities, public or private institutions, and private corporations. If no funds are exchanged, such collaborations do not qualify as CAS. However, if aviation is involved, LBNL staff must seek direction and approval of the APOC. Examples include:

1. Flying LBNL experimental equipment on board another entity’s aircraft as part of a collaborative project.
2. Flying another entity’s equipment on board an LBNL aircraft, most likely a UAS.
3. Flying as a guest scientist on another entity’s aircraft.

These or similar activities involving aviation are relatively rare and are therefore vetted and approved on a case-by-case basis through the APOC, who will determine the level of management approval and inclusion in work authorization documents as required based on the risk profile of the aviation activity. LBNL encourages such collaborations and the APOC will seek to expedite approvals as appropriate. Significant lead time may be required to validate the safety, for example, of flying LNBL equipment on a collaborator’s aircraft.

48.5.8.6 Data Management

All data from CAS flights must be downloaded, backed up and processed in accordance with project goals, objectives and requirements, and LBNL Data Management Policy (https://commons.lbl.gov/display/itdivision/Data+Management).

48.5.8.7 Summary of CAS work processes

48.6 Training Requirements

DOE Order 440.2c requires annual training for all individuals engaged in aviation activities. LBNL meets that requirement by scheduling training specific to the following sections of this Policy:

48.5.5 Unmanned Aircraft Systems

48.5.6 Unmanned free balloons

48.5.7 Moored balloons and kites

48.5.8 Commercial Aviation Services (CAS)

In cases where there is a lapse of activity in areas listed above that is longer than one year, training will be completed prior to restart of that activity.

It will also be possible to meet the aviation training requirement by completing the comprehensive aviation course provided by Embry-Riddle Aviation University (ERAU) through DOE HQ OAM.

Additional training is required by the FAA for UAS remote pilots. They are required to take recurrent training every two years or when new FAA regulations are implemented. The APOC or her/his designee tracks remote pilot certificate status and reminds remote pilots when recurrent training is due. Remote pilots must complete recurrent training on schedule in order to pilot sUAS for LBNL.

See Appendix A for additional information.

48.7 Procurement Requirements

All UAS, balloons and kites and related equipment used for conducting LNBL work must be purchased through the LBNL procurement system. Procurement of such items triggers notification of the LBNL LBNL APOC who will then contact the requestor, if such contact has not already occured. LBNL APOC ensures that the requestor is fully conversant with this Chapter. The LBNL APOC also reviews the procurement request, usually in conjunction with the requestor, to ensure that the UAS meets LBNL and DOE requirements for general air worthiness, aircraft performance specifications, ground control station performance (including frequency spectrum) and cybersecurity. Using the collective knowledge and experience of the LBNL and DOE UAS community, the LBNL APOC will advise the requestor on the suitability of the planned purchase for its intended purpose. Requestors are encouraged to contact the LBNL APOC prior to submitting procurement documents. In addition, all procurement of UAS must comply with Executive Order 13981 (January 18, 2021).

48.8 Maintenance Requirements

Maintenance requirements, including required documentation, are based on the specific activity involved.

48.8.1 Maintenance of UAS

Most UAS currently in use by LBNL staff are purchased as complete systems with limited maintenance requirements specified by the manufacturer. In such systems, maintenance commonly only involves replacement of propellers when they show signs of wear. However, pre- and post-flight inspections are considered an essential component of maintenance.

All maintenance must be performed by an LBNL Maintenance Technician (MT) or an appropriately qualified RPIC, or VO. Maintenance activities include:

1. Repairs and modifies UAS and ground control station and software, if needed.
2. Attaching and removing payloads to UAS as and if needed.
3. Attesting to UAS airworthiness, including weight and balance for the duration of each flight, after payload installation or removal, repair, replacement, maintenance, or modification.
4. Performing pre-and post-flight UAS inspections including airframe, payload (especially payload wiring connections) and rotors.

All maintenance must be documented in a UAS maintenance log specific to a particular UAS, or, in the case of pre-and post-flight inspections, in the RPIC’s flight log, or flight checklist.

Aircraft damage or performance issues without an obvious cause and means of correction, usually require that repairs be performed by the manufacturer or an authorized repair facility. Such repairs or modifications need to be documented as noted above.

For systems that are assembled from component parts, or that involve modification or change out of payloads, may require system testing and non-routine maintenance and updating of software. In such cases, maintenance, especially modifications to flight parameters must be reviewed by a second MT prior to flight and the review documented as part of the maintenance record.

48.9 Source and Reference Documents

U.S. Department of Energy (DOE)

Note: In the event of a “broken” link, a starting point is the DOE Office of Aircraft Management web site: https://www.energy.gov/management/office-management/operational-management/aviation-management

• DOE Order 440.2C (5-15-20) Department of Energy (DOE) Order 440.2C (September 15, 2020)
• DOE Commercial Aviation Services Accepted Operators List

Note: LBNL entities who hire or charter an aircraft service to conduct mission requirements may only select from the Commercial Aviation Services (CAS) Accepted Operators List.

https://powerpedia.energy.gov/wiki/Commercial_Aviation_Services_Accepted_Operators_List

Federal Aviation Administration (FAA)

Note: Web links change from time to time.In the event of a “broken” link, a reliable starting point is the FAA web site https://www.faa.gov or, for example, one level down, the Unmanned Aircraft Systems (UAS) section of the FAA web site:https://www.faa.gov/uas/ .

• 14 CFR Part 107 – Operation and Certification of Small Unmanned Aircraft Systems

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgFinalRule.nsf/0/18BECE69B1FE750786257FE00055D5C9?OpenDocument

• FAA –G-8082-22 – Remote Pilot – Small Unmanned Aircraft Systems Study Guide
  • https://www.faa.gov/regulations_policies/handbooks_manuals/aviation/media/remote_pilot_study_guide.pdf

• Register Your Drone
  • https://www.faa.gov/uas/getting_started/register_drone
• Become a Drone Pilot https://www.faa.gov/uas/commercial_operators/become_a_drone_pilot/#renew
• Renewing Your Part 107 Remote Pilot Certificate
  • https://www.faa.gov/uas/commercial_operators/become_a_drone_pilot/#renew

• Registering Your Drone with the FAA
• FAA UAS Flight Data Facility Maps
• Title 14 CFR Part 107, Small Unmanned Aircraft Systems.
• Title 47 CFR Part 87, Aviation Services.
• B4UFLY (iOS and Android App)

PART 101—MOORED BALLOONS, KITES, AMATEUR ROCKETS, UNMANNED FREE BALLOONS, AND CERTAIN MODEL AIRCRAFT

14 CFR 101 Subpart A – Moored Balloons, Kites, Amateur Rockets, Unmanned free Balloons, and Certain Model Aircraft

14 CFR 101 Subpart D – Unmanned Free Balloons

LBNL

Area Work Planning and Control for Experiments and Operations Subject Area (https://wpc.lbl.gov/ )

University of California

UC Center of Excellence Unmanned Aircraft System Safety

• https://www.ucop.edu/safety-and-loss-prevention/environmental/program-resources/unmanned-aircraft-systems-safety.html

48.10 Appendices

Appendix A. Training and Certification Requirement for drone, balloon, and kite flight crewmembers

Remote Pilot in Command (RPIC) Qualifications

Remote Pilot in Command training shall include:

1. 14 CFR 107 remote pilot certificate required (drone flights only).
2. Manufacturer’s training program completion, if available.
3. Site-specific training, if applicable
4. 18 years of age
5. Training on the specific UAS described in the ASP shall be documented and maintained with respect to:
   1. Airworthiness
   2. Flight characteristics
   3. Weight and balance
   4. Lost communication procedure
   5. Loss of GPS/auto pilot
   6. Manual flight/control
   7. Ground control station (GSC) operation
   8. Initialization/checkout
   9. Frequencies and frequency mitigation/deconfliction
   10. Launch, landing/flight termination
   11. Normal and emergency procedures
   12. Limitations
6. Demonstrated competency by completing 10 hours of manual control of each UAS (5 hours of which may be logged via simulator), including an actual 20 manual take-offs and landings (i.e., not simulated); and documenting these items in the RPIC’s personal logbook.

Note: A person who is not qualified as a RPIC may operate the UAS under the direct supervision of a qualified RPIC if the qualified RPIC can immediately take direct control of the UAS (e.g., using a buddy cord and separate control box).

In addition, the RPIC must have made three manual takeoffs/launches and recoveries/landings within the 90 days preceding the UAS operation with the specific UAS stated in the ASP to qualify as the RPIC for the UAS operation. Simulation trainers will not satisfy this requirement.

Visual Observer (VO) Qualifications

The VO is a required position that provides increased situational awareness and safety to a UAS operation. The primary role of the VO is to see other traffic and hazards and report them to the RPIC. The VO fulfills the requirements set forth in 14 CFR Parts 91.111 and 91.113. The VO must have 20/20 (corrected) vision.

VO training shall include:

1. Site-specific training (e.g., site characteristics and requirements, COA requirements)
2. Instruction on the flight characteristics and limitations described in the Aviation Safety Plan for the UAS they will be observing
3. Identifying weather changes and trends that could impact UAS operations
4. Understanding cloud clearances, VFR minimums, minimum ceiling and visibility requirements based on the operating airspace and the ASP weather minimums
5. Communications to the RPIC
6. Radio procedures and discipline
7. Identification of traffic and hazards to the RPIC with relative position and altitude
   1. During circling flight, the compass method is recommended
   2. During straight flight, the clock method is recommended
8. CTAF and aircraft pattern entries and positions in a traffic pattern
9. Demonstrated competency by directly observing at least 1 hour of UAS flights prior to serving as a VO.

Maintenance Technician (MT) Qualifications

The MT maintains the UAS in airworthy condition per the OEM, FAA, and/or Airworthiness Statement.

Note: At LBNL, the RPIC or VO typically perform this function.

Where applicable, the MO should be familiar with the basic operation of the UAS, and the technical documents and requirements to repair and maintain airworthiness of the UAS. Training on the specific UAS described in the ASP with respect to construction, repair techniques, system functions, troubleshooting, airworthiness criteria, operation, and flight dynamics and limitations. Training may be provided by the UAS manufacturer or by the maintenance technician reading the UAS manufacturer’s manuals and procedures.

Appendix B. Risk Assessment for UAS, Balloon, and Kite Operations

Click here to access Appendix B guidance.

This link provides access to the Risk Assessment protocol outlined in FAA Advisory Circular AC-107-2:

• https://www.faa.gov/documentlibrary/media/advisory_circular/ac_107-2.pdf

Please note that the following points must be included in the risk assessment:

1. Air Traffic: Risk due to proximity to flight operations at regional airport or airfield.
2. Aircraft Hazards: Risk due to collision with a person, a structure, power lines, events, etc.
3. Ground Obstructions: Risk due impact with ground obstructions.
4. Physiology: Risk due to impacts of the environment on personnel.
5. Mission Profiles: Risk of delay due to disruptions in mission implementation.
6. In-flight Hazards: Risk due to in-flight hazards (aircraft, emergency procedures, etc.)
7. Collision with Structures: Risk due to (1) open field flying and/or (2) flying near structures.
8. Landing: Risk to safe landing.

For each of the 8 points outlined above, and based on the anticipated flight conditions, a “risk likelihood” vs “risk severity” is assessed using the Risk Assessment Chart on Page 86 and in FAA Advisory Circular AC-107-2.

Appendix C. Logging UAS (drone) Flights

All UAS (drone) flights must be logged in a manner that is readily accessible and permanent. Logging of free balloon, and moored balloon/kite flights is not required by the FAA. However, LBNL staff and affiliates conducting such flights are encouraged to log them as well. Flight logs are the responsibility of the RPIC and should be recorded both as a record of flight parameters for the RPIC and as a record for the project funding the flight. Acceptable logging methods include the following.

1. A paper record in a typical pilot log book
2. Smart phone app dedicated to flight logging (must enable some form of verification or electronic signature, backups and exportable copies)
3. Table in a spreadsheet or word processing file (this is the least desirable method)

For UAS flights the preferred option above is 2. However the app needs to meet certain requirements as noted. Typically apps specific to UAS will work best for all LBNL aviation activities as opposed to apps for manned aircraft pilots. There are many smartphone apps available for this purpose, several of which are rated 4 stars or greater. A number of websites also provide reviews of apps. Ideally, an app will output totals in a manner that facilitates required RPIC reporting for DOE-OAM.

The DOE requires that documentation of all operations associated with UAS activities be submitted on a monthly basis to the DOE Office of Aircraft Management. Reports are submitted by LBNL pilots to the LBNL Aviation Point of Contact or its designee. Reports of flights to DOE must be backed up by logged flight records.

Note: Practice and mission flights must be logged and reported each month.

The following information must, at a minimum, be reported by RPICs to the APOC (or designee) each month:

1. Number of flights
2. Date, time and Duration of each flight (to the nearest 10th of an hour)
3. Latitude-Longitude or other uniquely identified location of each flight.
4. UAS platform (manufacturer and model)
5. Total number of flight hours.
6. Report flight controller and pilot duty hours separately if different from flight hours

If there are any issues with the flights, such as lost links, aircraft damage, near-misses, etc., those need to be reported and will be included in the monthly report to DOE-OAM.

It is also possible to log all flights as they occur on a spreadsheet that is shared with the APOC. The APOC or designee can then complete the DOE report as required. The spreadsheet used for reporting COA flights to DOE-OAM is not suitable for logging flights, but is available here for reference.

Appendix D. UAS (drone) Flight Crew Responsibilities

The following summarizes the key responsibilities of each flight crew member.

Remote Pilot in Command (RPIC)

The Remote Pilot in Command shall:

1. Assure the safety and compliance of UAS operations with this procedure, applicable regulations (e.g., 14 CFR 91 and 14 CFR 107 as applicable to the specific flight), site requirements, and the applicable Aviation Safety Plan.
2. Obtain a LAANC authorization number when using a LAANC approval for UAS operations conducted under 14 CFR 107
3. Request the FAA to issue NOTAMS within 48 to 72 hours before UAS operations when a NOTAM is required. See Appendix G.
4. Ensure that the local aviation community is notified of UAS operations when appropriate.
5. Coordinate international UAS deployments through the responsible in-country representatives.
6. Determine the required crew for each AFC, EE, or UAS flight and assign duties to crew members.
7. Obtain a weather report, Temporary Flight Restriction (TFR) status, and Notices to Airmen (NOTAMs) pertinent to the UAS flight. See Appendix G.

Note: The RPIC must be familiar with all airports, navaids, airways, military training routes, and any other aviation assets that may be used by manned aircraft in the vicinity (e.g., within 10 miles) of the UAS operation.

Verify readiness to conduct flights, including:

1. UAS airworthiness
2. Payload attachment
3. Ensure weight and balance within limits
   1. Ground station control and operability
   2. Lost-link functionality
   3. Sufficiency of fuel or battery for the aircraft to return from its furthest distance from the landing point and safely land plus an additional 10% of fuel or battery
   4. Readiness and qualifications of each crew member to perform their assigned duties
   5. COA approval and ability to comply with COA requirements
   6. A LAANC authorization number has been obtained when using a LAANC approval for UAS operations conducted under 14 CFR 107
   7. Applicable NOTAMs have been posted on the FAA website. See Appendix G.
4. With the PI, if applicable, define the flight patterns required to achieve the AFC or EE objectives.
5. Conduct a Plan-of-the Day Briefing with the flight crew, PI, reviewing the science objectives, flight patterns, emergency response procedures, weather, UAS and instrumentation readiness, flight crew readiness, and any other factor important to safe execution of the day’s flights such as deconfliction with other flight operations.
6. Conduct a preflight briefing with the flight crew and RSO (if assigned) before each flight covering flight patterns, emergency response, and readiness to conduct the flight.
7. When using more than one Visual Observer (VO) to extend the UAS range:
   1. Ensure VOs are properly trained
   2. Ensure the transition/handoff procedures between VOs is thoroughly briefed and understood
   3. Ensure there is adequate overlap of the visual range between VO positions.
8. Assure that proper approval has been obtained for each flight, mission or campaign.
9. Announce the start and end of UAS daily operations on the appropriate Common Traffic Advisory Frequency (CTAF) as required.
10. Monitor the CTAF during UAS operations as required.
11. Execute each UAS flight (i.e., controls, or monitors the control of, the UAS through all phases of flight).
12. Provide for the safe execution of PI inputs during the flight to facilitate achieving the science objectives in accordance with the approved ASP.
13. Maintain communication capability with the Visual Observer(s) during the flight.
14. Conduct post-flight briefings to identify opportunities for improvement.
15. Record entries in the applicable Flight Log.
16. Record and maintain a one-year record of the LAANC authorization number(s) when operating UAS under Part 107 with a LAANC authorization.
17. Report incidents/accidents.
18. Report flights monthly to the LBNL APOC or his/her designee

All UAS flight crew members and the PI are prohibited from participating in a UAS operation if they have consumed any alcoholic beverage within the preceding 8 hours, is under the influence of alcohol, is using a drug, including over-the-counter drugs, that affects the person’s mental or physical capabilities, or has a medical condition that creates an undue risk.

Note: At LBNL the PI or the Field Site Manager may also be qualified as the RPIC.

Visual Observer (VO)

The VO has the responsibility to advise the RPIC of imminent hazards to flight. The VO must be able to see the UAS with vision that is unaided by any device other than corrective lenses throughout the entire flight.

The Visual Observer (VO) shall:

1. Watch the UAS location (attitude, altitude, direction of flight) and watch for approaching aircraft and notify the RPIC when other aircraft are seen that may pose a hazard/conflict. Aids to vision such as binoculars may be used on a short-term basis, but not as a method to increase the line-of-sight distance.
   1. The VO has the authority to recommend the RPIC to alter course and/or altitude to mitigate traffic conflicts.
2. Observe weather and visibility conditions and warn the RPIC of approaching weather adverse to UAS operation; e.g., wind speed aloft and at ground level, frontal movement, lightning, declining visibility.
   1. The VO has the authority to recommend the RPIC to land the unmanned aircraft if conditions appear to exceed UAS limitations.
3. Maintain effective communication via direct voice or radio with the RPIC at all times.
   1. Cell phones may be used, but the phone must be continuously connected to the RPIC during the entire flight. This is the least desirable choice and should not be the primary method of communication.
4. Not act as VO for more than one UAS at a time.
5. Not act as VO and RPIC simultaneously.

Maintenance Technician (MT)

The Maintenance Technician shall:

1. Repairs and modifies UAS and ground control station and software.
2. Attaches and removes payloads to UAS as and if needed.
3. Attests to UAS airworthiness, including weight and balance for the duration of each flight, after payload installation or removal, repair, replacement, maintenance, or modification.
4. Records maintenance and/or modifications in the UAS maintenance log.

Note: At LBNL RPICs, PIs, or VOs are typically also qualified as MTs and thus a separate individual is generally not needed to function as an MT.

LBNL Principal Investigator, Field Site Manager or Designee (also referred to as “Requestor”)

Contacts Berkeley Lab Aviation Point of Contact (LBNL APOC). Prepares the Aviation Safety Plan (ASP) including safety analysis and airworthiness documents. Completes and submits FAA Certificate of Authorization request and documentation. Completes Berkeley Lab documentation. Conducts work in accordance with Policy.

As applicable, the Principal Investigator, Field Site Manager or Designee (Requestor) shall:

1. Ensure that WPC documents including the ASP required for UAS operations are approved and current.
2. Verify the training and qualification of the RPIC and VO.
3. Coordinate with the RPIC for Notices to Airmen (NOTAMs). See Appendix G.
4. Serve as the point of contact (POC) for users conducting UAS operations at the field site.
5. Coordinate any site infrastructure needed by users to conduct UAS operations, including frequency spectrum approval.
6. Review monthly flight reports generated by the LBNL APOC or his designee to verify accuracy.
7. Assist the LBNL APOC in ensuring compliance with this chapter.
8. Establish the science objective for each flight and conveys the objectives to the RPIC.
9. In conjunction with the RPIC, determine the flight paths needed to safely achieve the science objectives.
10. In conjunction with the RPIC, establish both the minimum and optimum weather requirements for flight in advance of the campaign.
11. Verify and monitor payload operability and data transmission before and during flight as applicable.
12. Provide input/requests to the RPIC during each flight regarding changes that may be needed in the flight pattern (e.g., altitude; loitering) to facilitate achieving the science objectives.

Appendix E. Aviation Safety Plan Example

The Aviation Safety Plan presented below is an example. It is also provided as a template. Click here for access to the template, which can be freely edited to reflect project specifics.

INSTRUCTIONS

1. The following document provides an example to facilitate the development of a project-specific Aviation Safety Plan (ASP). The ASP is the official, guiding document and must reflect the mission, risks, etc, of the project. As such, it is an internally and externally auditable document. The Project Lead, who may also be the PI and/or RPIC, is responsible for its content and implementation.
2. The document highlights the areas that need to be customized per the project parameters.  Areas that are not highlighted are standard language that may be edited freely to reflect the project specifics.
3. All documents referred to in the Attachments section of this document should be uploaded to the attachments section of the WPC Activity.
4. The Description of Work in the WPC Activity should be synced to this ASP; however, the Description of Work in the WPC Activity does not need to be as comprehensive as this ASP and can refer to the attachment for the full version.
5. If minor changes to the ASP are required (e.g., updating equipment, adding/deleting crew names, documentation of a new COA, etc.), they may be made without reauthorization of the Activity. Major changes to the ASP (e.g., scope of work, location, mission, risk, etc.) are required, the WPC Activity must be reviewed and reauthorized. Contact the APOC for guidance.
6. This is an example, not a template. The owner of the document must create content that reflects project specifics. Click on the template link provided above to develop a project-specific ASP. Red font Note comments provide additional points that must be addressed by the creator.

LBNL Aviation Safety Plan (ASP) for UAS (Unmanned Aircraft System) Flights

Project: Title and related information

Work Planning & Control Activity: Alphanumeric identifier

Summary

Location: Insert location(s) where flight operations will be conducted. This may involve generalizing, but it is important to provide sufficient specificity (i.e., “various locations involving…”, “urban areas in proximity to…”, etc.) to describe the basics.

COA: NOTE: The Blanket Area UAS Class G COA (DOE) in effect as of publication of this example is subject to change. Contact the APOC for the current version. NOTE: Include the current COA as an attachment to the WPC Activity.

UAS: Drone make/model; drone serial number.

ASP Dates: Date-to-date (time span, not to exceed one year). NOTE: The ASP must be revised any time there is a material change in the activity. The Activity must be reviewed annually.

Overview

Project Principal Investigator: PI name, division/organization/ LBNL

Point of Contact for aircraft Activities: Name and LBNL email address

Project: Name of project

Sponsor Program Manager: Name of sponsor

Project goal: Describe project goal

Key instrumentation: Describe the instruments (payload), if applicable.

Aircraft platforms: Describe the UAS(s) to be deployed

Location of planned flights: Describe the locations of flights

Dates of planned flights: Provide a date range, e.g., September 1, 2019 – 30 September 2020

Current status of Certificate of Authorization: The Blanket Area UAS Class G COA (DOE) in effect as of publication of this example Policy is 2021-ESA-9226-COA. It is subject to change. Contact the APOC for the current version. NOTE: Check to ensure you have the most current version.

LBNL Approvals: Approved by DOE Bay Area Site Office (BASO) Aviation Safety Officer (ASO) in coordination with the LBNL Aviation Point of Contact (LBNL APOC). This Activity is addressed as Work Planning and Control Activity XX-0000.

Aviation Safety Plan Outline

1. Introduction
   1. Regulations and requirements

2. Aircraft Requirements
   1. Aircraft
   2. Operator
   3. Airworthiness review and approval
   4. Crew size and composition

3. Equipment description
   1. Airframe and payload
   2. Launch
   3. See and avoid

4. Communication

5. Mission description
   1. Pre-Operation
   2. Crew Special Requirements
   3. Debriefing

6. Hazards & Risk Assessment
   1. Air Traffic
   2. Aircraft Hazards
   3. Ground Obstructions
   4. Physiology
   5. Mission Profiles
   6. Potential Inflight Hazards

7. Emergency Reporting and Contacts

8. Responsibilities

9. Attachments

1. FAA Remote Pilot’s License Certificates
2. Certificate of Registration
3. Unmanned aircraft Systems Risk Analysis Metrics
4. Certificate of Waiver or Authorization (COA – 2019)
5. Current Airworthiness Declaration
6. Notification to HQ OAM Senior Aviation Manager (Form 19)

1. Introduction

NOTE: Provide sufficient detail in this section to inform the reader about the purpose, equipment, detectors, etc. Make sure it reflects your equipment and operating conditions.

NOTE: This is an example of an Aviation Safety Plan. Areas that will need to be project-specific are highlighted throughout.

The project team will deploy a small unmanned aircraft system (UAS) during research activities. A (insert drone make/model number) will be used. The UAS platform will be equipped with a XXXX used to detect YYYY. The YYYY is detected and used to quantify ZZZZ. Data collected during flights will be used for development and improvement of real-time software and algorithms for data mapping and localization.

1.1 Regulations and Requirements

UAS flights and related activities will be conducted in accordance with DOE Order 440.2C, LBNL Aviation Safety Policy, relevant parts of Title 14 of the Code of Federal Regulations (Federal Aviation Administration, 14 CFR), and all specific regulations of another sovereign airspace authority when the mission is outside of the United States.

Note: This blanket COA is not valid nor can it be used outside the United States. For foreign missions, the local/country rules will apply.

UAS flights will be conducted under the Blanket Area UAS Class G COA (DOE) 2019-AHQ-907-COA. NOTE: This is subject to change. Check with the Aviation Point of Contact to ensure the current COA is included.

Flight operations will be conducted exclusively in Class G airspace. Flight operations conducted under this Plan will typically be limited to 400 ft AGL, but the current COA accommodates up to 1200 ft. AGL.

The UAS used in this project is considered an Approved Unmanned Aircraft System per the manufacturer’s airworthiness statement. Airworthiness is maintained by Remote Pilot in Command (RPIC) by inspection prior to and after each flight.

The aircraft employed in this project has/have been registered with the FAA.

2. Aircraft Requirements

2.1 Aircraft

Only one UAS will be operated by each operator (e.g. Remote Pilot in Command (“Pilot”) or designee under direct supervision of the pilot) at any given time at a given site. UAS deployed for this project is an LBNL-owned (insert drone make/model number). Additional UAS may be acquired through LBNL and will be subject to the same requirements as included in this Aviation Safety Plan.

The (insert drone make/model number) utilizes the following features (per the manufacturer).

• AES-256 Encryption. Per the manufacturer, The AES-256 encryption keeps data transmission secure.
• Obstacle Avoidance. The drone is equipped with an onboard system employing front, bottom and upper sensors that detect and aids in avoiding obstacles while enabling precision hovering.
• Anti-collision Beacon. The drone is equipped with latest generation top and bottom anti-collision beacons for visibility at night or in lowlight conditions.
  • Note: While paragraph G of the DOE Blanket COA, allows UAS operations to be conducted at night, this project will not involve night or impaired visibility flights.
• DJI AirSense. This drone has a built-in ADS-B receiver, called DJI AirSense. This technology enhances airspace safety by automatically providing the operator with real-time information about nearby airplanes and helicopters.
• Note: There is a recognized potential for data gathered by a DJI drone to be transferred to unauthorized collection points if the drone is connected to the internet for update/file download. Precautions will be taken to prevent unauthorized collection of data.

2.2 Operator

All DOE/LBNL-owned UAS will be operated by trained LBNL UAS pilots who have been certified as FAA Remote Pilots under Part 107 or by personnel under the direct supervision of the FAA-certified RPIC. The RPIC operating or supervising UAS’ under this project must hold a FAA Remote Pilot Certificate and be prepared to produce it if requested. In addition, while there is no requirement for medical certification, any certified pilot or observer on this project will self-certify that they are capable of performing the job safely.

All FAA Remote Pilot Certificates are included in Attachment 1. This attachment will be updated as additional operators receive their FAA certificates.

2.3 Airworthiness review and approval

An Airworthiness Certificate (AC) is not required by the FAA for small UAS operating under Part 107. However, it is required by the DOE. The AC(s) for the drone(s) must be kept with the UAS kit. It should also be included in the attachments and is an attachment to the WPC Activity.

Note: Except for small unmanned aircraft operating under 14 CFR part 107 or a part 107 waiver, a civil UAS cannot conduct air commerce in the National Airspace System unless there is an appropriate and valid airworthiness certificate issued for that UAS. U.S. registration is a prerequisite for the issuance of an airworthiness certificate.

2.4 Crew size and composition

The project team/operations crew for all UAS flights comprises a minimum two-person ground crew: a Pilot and Airspace Observer. Neither the Pilot nor the Observer is allowed to serve both functions at the same time. All RPICs and Observers must meet training requirements specified by DOE HQ OAM and the DOE Blanket COA. RPIC qualification will be documented in the UAS Notification to DOE HQ OAM Senior Aviation Manager.

Name Crew Function

Name (LBNL) Pilot/Payload Specialist/Airspace Observer

Name (LBNL) Airspace Observer

Name (LBNL) Payload Specialist/Airspace Observer

This ASP and the Work Planning and Control Activity (XX-0000) will be updated whenever there is a material change in crew status or certification.

3. Equipment Description

3.1 Airframe and Payload

The (make/model number) UAS (shown in Fig. 1) is battery powered and equipped with visual camera (i.e., brand name), which is a high-resolution camera (20.8 Mega Pixels) that can be used in still (capturing static pictures) or video mode. This system has also been paired with a (make/model number) camera, which is a high definition (640 × 512 resolution) thermal camera that has an infrared sensor, which can spot pixel temperature with a relatively good precision. Ground controllers are systems developed by the manufacturer (i.e., make/model number). Per the manufacturer data and the position are encrypted and are not automatically transferred to the manufacturer

Figure 1: (drone make/model number)

NOTE: Include a statement attesting to the fact that data or position information cannot be transmitted by the UAS. This is a DOE requirement.

3.2 Launch

UAS launch standard procedures are as follows:

• Physically inspect UAS to ensure airworthiness
• Select an open area clear of immediate obstacles
• Clear the area of personnel except crew.
• Pilot and Observer scan the area and sky to confirm takeoff conditions are clear. Personnel are kept at least 30 feet from spinning rotors during takeoff/landing.
• Check mounting provision for tightness and security of all components that are removable for transporting to and from the flying site.
• Check the payload to ensure that it is securely mounted onto the UAS.
• Controller is checked and turned on.
• UAS is placed on the ground and powered on.
• Controller displays aircraft telemetry. Pilot confirms battery voltages and signal strength of GPS.
• Pilot and Observer recheck immediate area and sky.
• If clear for takeoff, Pilot announces “Takeoff” and engages UAS motors.
• Pilot brings aircraft into a stable hover approximately 6’ off the ground and reconfirms all flight controls, battery voltages, and data-link signal strength.
• Pilot and Observer fly the mission.
• During flight, Pilot and Observer continue to scan the sky and immediate area and note any personnel, aircraft, aircraft obstacles, or weather that could pose a safety hazard. Pilot constantly scans telemetry data from the aircraft monitoring battery voltages, RF signal quality, altitude, and GPS data.
• The UAS will be operated in return-to-home mode, where it returns to a home location in case the connection link with the remote control is lost.
• Flight time will be logged for future activity reporting using the HQ OAM supplemented form (sample attached). Data will be reported monthly to OAM, irrespective of whether flights have been conducted. Data reporting will be coordinated with the LBNL Aviation Safety Point of Contact.

NOTE: a model checklist is included in the Aviation Safety Policy and should be applied here. It is recommended that it be included as an attachment to the ASP if it or a modified version will be used.

3.3 See and Avoid

The Pilot will maintain a visual line-of-sight with the UAS at all times. As per FAA requirements, visual line-of-sight is unaided. The Observer will also constantly maintain line-of-sight with the aircraft and warn the Pilot to avoid any condition that would place the aircraft out of line-of-sight, as well as warn of any aircraft in the region of flight. The Observer will also guide the Pilot in preventing collision.

4. Communications

Ground controllers used for each UAS comply with part 15 of the FCC Rules. The DJI Matrice 210 V2 controller communicates on either a 5.725 to 5.825 GHz or 2.400 to 2.483 GHz frequency.

Maximum transmission distance, free of interference, for the DJI Matrice 210 V2 controller complies with the FCC (5 miles) and CE (3.1 miles) rules.

Communication between the Pilot and Observer consists of direct verbal communication when both are co-located. If it becomes necessary for the Observer to move away from the Pilot, cell phone communication will immediately be initiated to maintain contact. At remote sites, coverage will be confirmed prior to flying. When cell communication is not effective, an equivalent method for communication between pilot and observers will be established (portable radio, satellite phone, etc.).

5. Mission Description

5.1 Pre-Operation Briefings

Operations team briefings will be held before and after flights to ensure that all team members are aware of safety requirements, flight plan and procedures, and general operations.

Prior to flight, the operations team will review the following:

• Weather, including wind conditions
• Altitudes and flight path
• Mission overview, including handoff and recovery procedures
• Frequencies to be used
• Flight time limitations, including battery charge requirements
• Contingency procedures to include lost link, divert, and flight termination
• Any hazards unique to the flight being flown, including issues and/or special provisions related to proximity to the public.

NOTE: a model checklist is included in the Aviation Safety Policy and should be applied here. It is recommended that it be included as an attachment to the ASP if it or a modified version will be used.

5.2 Crew Special Requirements

Crew special requirements include special responsibilities and required safety training or information briefings as follows.

All team members:

• Must have a working knowledge of this Aviation Safety Plan.
• Must understand and comply with the stipulations set forth in the governing Work Planning & Control Activity (XX-0000).
• Formally accept the Work Planning and Control Activity controls profile prior to participating in flight operations.
• Must conform to all LBNL WPC Activity requirements, whether participating in flight operations or data collection.
• Implement hazard controls according to site risks and identified controls.
• Comply with local site rules and regulations.

In addition to general team member requirements:

Pilot in Command:

• Responsible for overseeing all UAS operation and flights, and serves as the authority on takeoff, landing, and flight termination.

Observer(s):

• Responsible for maintaining a direct line-of-sight with the UAS and assisting the Pilot with UAS operations. The Observer role is essential to ensure safe UAS operation and will remain focused on the flight and alert to changing operating conditions. Manned aircraft always have the right of way.

5.3 Debriefing

After the flight, operations team will debrief to review the following:

• Areas that were successful and areas that need improvement for all phases of the operation, including:

• Planning
• Preparation
• Takeoff
• Mission
• Landing

• Items to consider for modification or improvement
• Equipment assessment
• Procedures assessment
• Internal and external coordination issues
• Data collection and management

NOTE: a model checklist is included in the Aviation Safety Policy (Appendix H) and should be applied here. It is recommended that a checklist specific to flight operations covered by the ASP be included as an attachment to the ASP.

6. Hazard Risk Assessment

Hazards in this section will be discussed and assessed in accordance with the Risk Analysis Chart. The process for making the Hazard Risk Assessment is included in Appendix B of this document. Each risk will be assigned a Risk Analysis Chart (RAC) code of I through IV based on the likelihood and consequence of an occurrence and the RAC chart (see Table 2).

6.1 Air Traffic

The operations site may vary. FAA Part 107 regulations will be observed with respect to flight operation proximity to controlled air space.

The LBNL Remote Pilot in Command has the responsibility to verify the following:

• Notification of local Air Traffic Control Center, if applicable per Part 107.
• Confirmation that a NOTAM will be issued for the planned operating period (as applicable and depending on location of flight operations).
• Local host coordination has been made, approved, and scheduled, if applicable.
• Defined communications and equipment are operable.
• The observer is properly equipped and briefed on role and responsibilities.
• Established procedures are followed if a local Search and Rescue (SAR) effort is in conflict or there is unplanned air traffic observed.

The closest regional airport at each location will be identified to account for any potential air traffic risk issues. However, mission plans will always ensure that the UAS will remain within Class G airspace, thereby making the risk of UAS and commercial aircraft collision negligible. Flights under this Work Planning and Control Activity won’t exceed 400 feet AGL.

If there is any doubt regarding the proximity of flight operations to a regional airport or airfield, the local Air Traffic Control center will be contacted and advised of planned flight operations in advance to ensure compliance with FAA regulations.

Summary – Air Traffic Risk Issues (per Attachment 4, Table 1 and 2):

Likelihood: Insert
Consequence: Insert
RAC: Insert

6.2 Aircraft Hazards

The primary hazards posed by the UAS may include collision with a person on the ground, a building, or power lines. Where applicable, the project team will work with the location facilities management/owner/etc. to define the flight zone to mitigate risk to uninvolved personnel at the host location and nearby power lines.

Flights will primarily be conducted in an open field with no ground obstructions. However, several flights may be conducted around a building. When flying around buildings, an adequate and safe standoff distance from the building will be established. Flight plans will be tailored towards the hazards associated with the open field or research building during pre-flight briefings with the project team and the host location POC.

Where flight operations will take place in close proximity to buildings or other inhabited areas, controls will be established to ensure that contact with the UAS and personnel or buildings will not occur.

Summary – Aircraft Hazards (per Attachment 4, Table 1 and 2):

Likelihood: Insert
Consequence: Insert
RAC: Insert

6.3 Ground Obstructions

Primary hazards for ground obstructions may include other people, trees, or buildings. The project team will work with host location Point of Contact (POC) to mitigate ground obstruction risks as stated in 6.2.

Ground Obstruction Risks (per Attachment 4, Table 1 and 2):

Likelihood: Insert
Consequence: Insert
RAC: Insert

6.4 Physiology

Team members will wear the proper PPE and will be briefed on the appropriate clothing to wear to mitigate the effects of temperature and weather changes.

Physiology Risks (per Attachment 4, Table 1 and 2):

Likelihood: Insert
Consequence: Insert
RAC: Insert

6.5 Mission Profiles

Planning

Initial mission briefing will typically take place at LBNL prior to departure for the operational location.

Setup

Setup will occur at the flight location. No specific safety equipment is required, and all participating team members from LBNL will, as applicable, adhere to host location safety requirements, as well as the requirements specified in the LBNL WPC Activity (XX-0000). This includes ensuring that the flight area has been cleared of non-participating personnel and clearly marking off the flight area to ensure that non-participating personnel conducting business at or in close proximity to the site are aware of ongoing flight activities.

Under no circumstances will flight operations be conducted over any personnel who are not part of the aircraft operation unless those people are in a covered structure strong enough to provide substantial protection from the UAS if it were to hit the structure.

There is no significant physiology risk as assessed above.

Startup

Initial flight preparations will be reviewed in-depth at the operational site again by all flight team members, including the flight plan, hazards, safety requirements, and personnel roles.

Weather conditions will be reassessed prior to and during each flight at the site to determine whether conditions pose a hazard to flight operations.

Takeoff

UAS take-off procedures as outlined in Section 3.2 Launch Procedures will be followed. An additional sweep of the flight area will be conducted shortly prior to takeoff to ensure that the area is clear.

Pilot will verbally alert every one of the launch prior to takeoff, and ensure that the Observer is in position and ready. Under no circumstance will a flight be initiated without cross-check by the Pilot and the Observer.

Initial Climb

The UAS will ascend in Class G airspace to as high as (specify XXX feet) above ground level, and not further than visual line of sight. No specific safety equipment is required.

Cruise

Upon reaching an initial altitude, the UAS will fly following pre-defined pattern (e.g., grid, circular, polygon) around the test building, depending on the building geometry. All activities for a given flight will be included in the flight plan and discussed in the pre-flight briefing with team members.

Summary – Mission Profile Risks (per Attachment 4, Table 1 and 2):

Likelihood: Insert
Consequence: Insert
RAC: Insert

6.6 Potential Inflight Hazards

Cruise Hazards

The likelihood of a mid-air collision with piloted aircraft or other UAS is extremely improbable due to the very low flight height < XXX ft and slow flight speed (X ft/s), long distance (more than 5 miles) from the nearest regional airport, and careful coordination with host location officials to ensure no overlap with other researchers in the designed test site. As such, the likelihood of catastrophic consequences, such as building damage, environmental impact, serious injury or fatality, is negligible.

Unplanned Egress from Airspace

An unplanned egress from airspace could result from winds higher than the airspeed blowing the UAS off course. To mitigate any risks, wind and other weather conditions will be assessed on-site during the setup and pre-flight debriefing, and UAS flight plans will be canceled in the event of strong winds. The flight path area will be designed to account for potential winds blowing the UAS off-course by at least 30 feet horizontally to avoid risks involving ground obstructions. The threshold wind speed at which flights will be stopped is 10 m/sec. The flight operations team will constantly monitor changing wind speeds using a digital anemometer. Wind speed is checked prior to initial flight, and flight plans are shifted or canceled dependent upon wind conditions.

Summary – Inflight Hazards (per Attachment 4, Table 1 and 2):

Likelihood: Insert
Consequence: Insert
RAC: Insert

Collision with Surface Infrastructure

The risk of collision with surface infrastructures will be assessed based on two types of flight plans: open field and building.

Open Field: The risk of collision with structures or personnel during test open field flights is low, as all flight operations will be conducted in a large, open field.

Buildings: During measurement flights around buildings, the risk of collision with a structure or personnel is slightly higher than the risk in the test field due to proximity of the flight path to the building (The closest distance will be 13-16 feet). However, as the UAS will remain within the line of sight and flying slowly the entire time, the consequences of collision with the building or personnel will be negligible.

The potential for light damage to UAS craft exists during all flight operations.

Practice flights may be conducted in open fields or in proximity to buildings. Practice flights will be treated the same as operational research flights in all respects, as outlined in the sections above. The proximity of the UAS to personnel, buildings, and other structures will always be given prime consideration before initiating flight operations.

Summary – Risk of Collision with a Structure in Test Field (per Attachment 4, Table 1 and 2):

Likelihood: Insert
Consequence: Insert
RAC: Insert

Summary – Risk of Collision with a Structure during Research Flights (per Attachment 4, Table 1 and 2):

Likelihood: Insert
Consequence: Insert
RAC: Insert

Landing

An open area by the test site will be designated for takeoff and landing. Prior to landing, the Pilot will communicate intent to land to the Observer, who will ensure that the landing area and flight path are clear for landing. The Pilot and Observer will also communicate to any participating personnel of the intent to land the UAS and clear the area. The Pilot and Observer will confirm approach and flight path and scan the area again to ensure it is clear. The Pilot will clearly announce “landing,” and reduce the aircraft altitude and speed for landing. The UAS will transition from flight to hover over the target landing spot and land. Motors and transmitters will be turned off, and batteries will be removed.

Summary – Landing Risks (per Attachment 4, Table 1 and 2):

Likelihood: Insert
Consequence: Insert
RAC: Insert 

7. Emergency Reporting and Contacts

In the event of an emergency requiring FAA notification, such as a collision with a building or personnel, LBNL personnel will immediately communicate the situation to the designated on-site LBNL representative (i.e., the Pilot in Command) and to the on-site location host POC, as applicable. The LBNL representative will serve as a point of contact with the local host location’s representative and the LBNL Aviation Point of Contact (who will notify the BASO Aviation Safety Officer, as warranted) to communicate detailed information about the incident. While highly unlikely, any potential impact of an emergency on civil air operations will be communicated to the local Air Traffic Control center as soon as possible, but no later than 6 hours following the event.

Per Section (your section), any injury, damage to property, impact on environment, or damage to the UAS must be reported to the Aviation Point of Contact by email as soon as possible.

Under no circumstances will a RPIC or Airspace Observer attempt to catch a UAS as it descends. This introduces the potential for a serious injury. Neither the value of the UAS nor that of its payload are a consideration.

This project may, in part or for the duration of its authorization, be subject to COVID-19 exposure controls. All work will be conducted in accordance with Chapter 46 of the LBNL Health and Safety Manual. In the event pandemic and/or operating conditions change, the project will comply with any restrictions arising from those changes, including but not limited to travel restrictions, quarantine requirements, and personal protection. All personnel will confirm health status via the LBNL COVID-19 Symptom Check on a weekly basis. It is the responsibility of the PI and RPIC(s) to ensure all crew members understand these requirements and comply accordingly. In the event host or local exposure prevention requirements are more rigorous than those of LBNL, then the host or local exposure prevention requirements will be followed.

The (drone make/model number) is also equipped with an emergency failsafe function to mitigate any risks associated with loss of signal between the transmitter and UAS. The Return to Home function is illustrated below, and the Record Home Point function will be included as part of pre-flight preparations before each flight involving the UAS make/model).

Figure 2: (insert drone make/model) Failsafe Return to Home Illustration

8. Responsibilities

(Insert name) will be responsible for coordinating Work Planning & Control Activity changes – including changes to the Aviation Safety Plan and related documents – with the LBNL Aviation Point of Contact.

As applicable, the PI will coordinate with local officials to ensure all safety procedures and flight operation information have been communicated to participating personnel. LBNL and DOE requirements will always be observed. In the event that research operations are conducted outside the United States, local in country UAS requirements will also be followed.

The LBNL Pilot in Command at any time during the project will be responsible for piloting the UAS following FAA regulations, obtaining weather reports, and conducting briefings. The flight crew (pilot(s) and observer(s)) must read and follow any additional site-specific documents, the approved version of this safety plan, and other field safety requirements for the host location and the LBNL WPC Activity.

9. Qualitative Risk Assessment

Given the experience and training of LBNL UAS pilots, the short flight times, the low flight speed, low flight height, and the restricted nature of host locations (as applicable, the overall probability of an incident is rated as “XXXXX”. Given the established controls for operating near buildings, the lack of air traffic, and the distance from the nearest regional airport (more than 5 miles), as well as the low cost and frangible nature of the UAS, the severity of an incident is rated as “XXXX.” Each individual risk has been assessed utilizing the risk assessment model in Table 1 and 2, and each area has been determined to be a RAC X or Y. This overall mission is therefore conservatively rated: RAC XXX – XXX Risk.

10. Approvals

I certify all information contained in this document is correct to the best of my knowledge and that it has been uploaded to the WPC Activity.

Date: XX/XX/XXXX (you may insert a copy of your signature)

__________________________________

Signature of LBNL Requesting Authority/PI

Name: XXXX

Division: XXXX

Subdivision: XXXX

Lawrence Berkeley National

Berkeley, CA 94720

Phone number: XXX-XXXX

Aviation Safety Plan — Attachments

Attachment 1. FAA Remote Pilot’s License Certificates

Insert name(s) and certificate(s) here. Also attach to the WPC Activity.

Attachment 2. Certificate of Registration

Insert photo of certificate here. Also attach to the WPC Activity.

Attachment 3. Unmanned Aircraft Systems Risk Analysis Metrics

Risk analysis considers the severity of a mishap and the likelihood that an incident will occur. The combination of severity and likelihood results in a “Risk Analysis Code” (RAC). The RAC helps identify the risk of flight operations and the required safety oversight, and ensures that missions are reviewed and approved at management levels appropriate to mission risks. In developing the risk scenarios consider the following:

• What is the UAS required to do?
• What is the environment in which the UAS and ground support component is working?
• What are the hazards in the entire system, and how could they impact the flight and mission?

It is helpful in risk analysis to develop risk statements in the “If/Then” format: If (this failure, mishap, or event occurs), Then (this worst case consequence that could occur). For example, “If GPS signal/navigation is lost during flight, then the UAS may crash into an existing infrastructure. A risk statement leads to estimating the likelihood that the risk will occur and identifying the control that prevents the risk from occurring or the mitigation that eliminates or reduces the consequence. Engineered controls are preferable to administrative controls (e.g., procedures, training). For the example cited, a control that would eliminate the consequence would be a lost link application in the UAS on-board controller that caused the UAS to fly in a loiter pattern at its last position until the GPS signal/navigation is restored or until manual control over the UAS is established.

Mishap Severity

Mishap severity is an assessment of the consequences of the most credible mishap that could be caused by a specific hazard. Mishap severity is a categorization that provides a qualitative measure of the most credible mishap resulting from flight crew error, environmental conditions, design inadequacies, procedural deficiencies, or UAS or component failure or malfunction. Rationale for the selection of hazards and the associated most credible mishap should be documented in the risk analysis section of the ASP. Definitions for mishap severity appear in Table 1 below.

Mishap Likelihood

Mishap likelihood is the assessment of the frequency that a mishap will occur during the planned duration of the UAS mission. Likelihood can be derived from historical data, or, for new UAS missions (e.g., a new UAS, ground station, instrument payload), from extrapolation of similar operations. Rationale for assigning mishap likelihood should be documented in the risk analysis in Section 9 of this Aviation Safety Plan. Definitions for mishap likelihood appear in Table 1 below.

Table 1: Severity of Consequences and Likelihood of Occurrence – Definitions

Table 2: Risk Analysis Chart

Source: FAA Advisory Circular AC-107-2

(also attach the risk analysis metrics to the WPC Activity)

Attachment 4. Current Certificate of Waiver or Authorization (COA)

(also attach the CURRENT COA to the WPC Activity)

Attachment 5. Current Airworthiness Declaration

(also attach to the WPC Activity)

6. Notification to HQ OAM Senior Aviation Manager (Form 19)

(also attach to the WPC Activity)

Appendix F. UAS Notification to HQ OAM Senior Aviation Manager (Form 19)

The DOE Office of Aircraft Management requires that Form 19 (as follows) be submitted with each Aviation Safety Plan. This supplements the Aviation Safety Plan (see Appendix E) and Work Planning & Control Processes. The form is reviewed by the Berkeley Site Office – Aviation Safety Officer, who will forward the document to the DOE Office of Aircraft Management for final review and approval.

LBNL remote pilots in command (and/or WPC Activity Leads) will submit Form 19 once for a given project. It remains in effect for the duration of the project unless there are material changes. Material changes could include but are not limited to:

1. UAS type or manufacturer
2. Research project location
3. Distance from a public use airport
4. Crew members

The following is an exhibit only. A downloadable version is available here.

Appendix G. Notice to Airmen (NOTAMs)

Protocol for Filing NOTAMS

NOTAMs are unclassified notices or advisories distributed by means of telecommunication that contain information concerning the establishment, conditions or change in any aeronautical facility, service, procedure or hazard, the timely knowledge of which is essential to personnel and systems concerned with flight operations.

A NOTAMS is filed with an aviation authority to alert aircraft pilots of potential hazards along a flight route or at a location that could affect the safety of the flight. With respect to LBNL UAS flight operations, an example would be a UAS pilot filing a NOTAMS if unusual or changing conditions could be reasonably expected and that could affect safety. Filing a NOTAMS is an exception, not a rule, but UAS pilots must be aware of the requirement, when applicable.

Note that NOTAMS filing is required by the COA per the text below (reformatted for clarity):

A Distant (D) NOTAM must be issued prior to conducting UAS operations not more than 72 hours in advance, but not less than 24 hours for UAS operations prior to the operation for routine operations. This requirement may be accomplished:

1. Through the proponent’s local base operations or (D) NOTAM issuing authority, or
2. By contacting the NOTAM Flight Service Station at 1-877-4-US-NTMS (1-877-487- 6867).

The issuing agency will require:

1. Name and contact information of the pilot filing the (D) NOTAM request
2. Location, altitude and operating area
3. Time and nature of the activity.

The area of operation defined in the (D) NOTAM must only be for the actual area to be flown for each day defined by a point and the minimum radius required to conduct the operation.

The operator must cancel (D) NOTAMs when UAS operations are completed or will not be conducted.

NOTAMS filing, as required under the COA, can also be accomplished by one of several commercially available software services, including but not limited to:

Aloft: https://www.aloft.ai

Skyward: https://skyward.io

Airmap: https://www.airmap.com

Airspace authorization when flying under Part 107 rules can be obtained in near-real time without third-party software using www.faaadronezone.faa.gov.

Lost Link Procedures related to NOTAMS

Lost Link Procedures:

In the event of a lost link, the UAS pilot will comply with the following provisions:

1. The UA lost link will be programmed to ensure that lost link flight does not fly over persons and the landing location is within the view of the RPIC.
2. Rally and home locations will be programmed to remain within the area defined in the NOTAM where flight operations are being conducted.
3. Lost link procedures will not transit or orbit over populated areas, Victor airways, or busy roadways/interstate highways.
4. Lost link procedures will be programmed to remain within the operations area and altitude, avoid unexpected turn-around and/or altitude changes, and will provide sufficient time to communicate with ATC if necessary.

Appendix H. UAS (drone) Pre-Flight and Post-Flight Inspection Checklist

The Chief Remote Pilot in Command is responsible for ensuring the following inspection items are incorporated to confirm operational safety as required by 14 CFR Part 107.

Note: PFIs are “post-fight inspection” items. Highlighted areas are mandatory. Additional information about checklists is available at:

https://jrupprechtlaw.com/section-107-49-preflight-familiarization-inspection-actions-aircraft-operation/

Documentation

• Work Planning & Control Activity approved
• Aircraft registration complete and registration number visible on aircraft
• Pilots and flight crew have personal identification (driver’s license or passport)
• Pilot(s) have Part 107 certificates (or temporary certificate) on their person
• Pilots and visual observers are in contact and understand roles
• COA (Certificate of Authorization) is current, understood, and readily available on site
• Copy of Aviation Safety Plan (ASP) immediately available on site

Operating Environment

• Local weather conditions acceptable
• Local airspace and any flight restrictions confirmed
• Location of persons, property and moving vehicles not directly participating in the operation confirmed and potential for entry into flight operations area anticipated
• Emergency procedures reviewed with flight crew
• Roles and responsibilities per flight plan have been communicated

Visual inspection of UAS condition

• Registration markings properly displayed and legible
• Control surfaces and airframe structure checked for signs of damage, loose hinges, and general condition PFI item
• Wings/rotors are in good structural condition and properly secured PFI item
• Motor/engine and mounting attachments to the airframe OK PFI item
• Compass calibrated
• Propellers/mounting hardware/rotor blades checked for chips and deformation ⇨ PFI item
• Landing gear condition and function OK, and no interference of cables or other obstructions with landing gear (if applicable) PFI item
• Electrical connections tested to ensure they are plugged in and secure ⇨ PFI item
• Photo/video or other payload mounting system checked, secure, operational PFI item
• Location of GPS equipment controlling the autopilot OK ⇨ PFI item

Start-up Sequence

• All component batteries sufficiently charged (includes batteries for UAS and control station)
• Frequency conflicts between video and transmitter/receiver resolved
• Drone placed in a level location safe for takeoff and landing, and safety of alternative landing confirmed (if applicable)
• Power up ground station, check display panel function
• Connect ground station to drone and then power up
• Check that control link established between aircraft and control station, including navigation and communication data links
• Inertial measurement module movements in the ground control software OK
• Control surfaces move towards the correct positions with UAS in stabilization mode
• Video receiver/goggles powered up, as applicable
• Camera system video recorder turned on
• Camera or other instrumentation payload settings OK
• SD camera memory cleared and inserted into the camera (or confirm sufficient remaining storage)
• Confirm unintended data transmission does not occur
• Confirm all transmitter controls move freely in all directions
• Confirm all transmitter trims are in neutral position
• Confirm all transmitter switches in correct position
• Transmitter throttle set to zero
• LED indicators and audible tones are correct
• Timer on (if applicable)
• Confirm First Person View (FPV) video is in monitor/goggles (as applicable)

Flight Sequence

• Scan for nearby vehicles/people/animals
• Say “CLEAR!”
• Start UAS propellers to inspect for any imbalance or irregular operation
• Throttle increased slightly to listen for any abnormalities
• Short 20-30 second hover at 3-5 feet (listen for vibrations/loose items)
• Confirm voltage levels are correct
• Verify all controller operations for heading and altitude
• Verify any noted obstructions that may interfere with the UAS
• At controlled low altitude, fly within range of any suspected interference and recheck all controls and stability
• Return to landing site and initiate automated flight path or continue flight as applicable

• Other: ___________________________________________________________
• Other: ___________________________________________________________

Landing sequence

1. Land aircraft (automated or manually as appropriate)
2. Shut down manually, if needed
3. Exchange batteries and conduct subsequent flights per flight plan, as applicable

Post-Flight Inspections/Debrief

• Conduct post-flight inspections (PFI), critique flight operations, and note any abnormalities below: ____________________________________________________________ ____________________________________________________________

Complete signature block below (required!!!)

Date and Start Time: ______________________________________________

Mission and Location: _______________________________________________

Remote Pilot(s) in Command: (Chief) _______________________________________________

_______________________________________________

_______________________________________________

Visual Observer(s): _______________________________________________

_______________________________________________

_______________________________________________

Person(s) Manipulating the Controls (if applicable): ______________________________________________

_______________________________________________

Aircraft (model and registration #):

1) ____________________________________________

2) ____________________________________________

3) ____________________________________________

4) ____________________________________________

WPC Activity Number: _______________________________________________

Number of Flights: __________________________________________________

Total Flying Time: _______________________________________________

Chief Remote Pilot in Command Signature:

_______________________________________________

ADDITIONAL NOTES:

Appendix I. FAA Advisory Circular AC-107-2

The link below takes you directly to FAA AC-107-2, which “provides guidance in the areas of airman (remote pilot) certification, aircraft registration and marking, aircraft airworthiness, and the operation of small Unmanned Aircraft Systems (UAS) in the National Airspace System (NAS) to promote compliance with the requirements of Title 14 of the Code of Federal Regulations (14 CFR) Part 107, Small Unmanned Aircraft Systems.

It does not provide, nor is it intended to provide, a legal interpretation of the regulations. Remote pilots are encouraged to use this information as best practice methods for developing operational programs scaled to specific small unmanned aircraft (UA), associated system equipment, and operations.

Use of this AC is intended to assist the remote pilot in meeting the requirements of applicable 14 CFR regulations.” (Quoted from AC-107-2).

https://www.faa.gov/documentlibrary/media/advisory_circular/ac_107-2.pdf

Appendix J. Accident Reporting Requirements

Emergency response planning that is part of the ASP shall include appropriate accident reporting requirements that meet the stipulations below.

All accidents must be reported within 12 hours to the Field Site Manager or designee, the LBNL APOC, the ASO, the Office of Science Aviation Safety Manager, and the DOE Office of Aviation Management if the accident meets any of the thresholds enumerated below. In order to ensure reporting of accidents that exceed the thresholds below within the 12 hour window, RPICs are required to report ALL aviation accidents to the LBNL APOC or designee within 2 hours, if at all possible. This is so that the APOC can assist the RPIC in determining thresholds and report to DOE-OAM and/or FAA as appropriate. Note that taking care of any injuries associated with the accident (including calling 911 if that is needed) always takes precedence over reporting.

The protocol for internal reporting of aviation accidents is as follows:

1. Send a text to the APOC, Kevin Goodwin (510) 708-8503 and his designee, Phil Long (509 531-2987) with the accident information listed below. Copy and paste the text into an email and send it to kegoodwin@lbl.gov, pelong@lbl.gov, and phillong@nwi.net.
2. Call the AOPC (Kevin Goodwin at (510) 708-8503 (cell). If no answer. leave a voice message alerting him to the text and email sent in step 1 above.
3. If the AOPC does not answer, call his designee, Phil Long at 509 531-2987 (cell). If no answer, leave a voice message alerting him to text and email sent in step 1 above.
4. Kevin Goodwin or Phil Long will respond to your call, email or text as soon as possible, asking for any needed clarification. The RPIC’s input on an assessment of which reporting thresholds have been exceeded is crucial. The determination which thresholds have been exceeded is the responsibility of the APOC. The APOC will work with the RPIC to develop any required reports. Typically, it is the APOC’s responsibility to transmit a report to OAM or the FAA.

Information to be provided to the APOC or his designee:

1. UAS remote RPICs name and contact information;
2. UAS remote RPIC’s FAA airman certificate number;
3. UAS observers name and contact information;
4. UAS registration number issued to the aircraft, if required (FAA registration number);
5. Location of the accident;
6. Date of the accident;
7. Time of the accident;
8. Person(s) injured and extent of injury, if any or known;
9. Property damaged and extent of damage, if any or known; and
10. Description of what happened.

Note that RPICs should not report to DOE-OAM or the FAA without fully coordinating with and being directed to do so by the APOC and/or LBNL EHS Management.

Accident Reporting Thresholds for reporting within DOE.

1. Results in an injury that:
   1. Requires in-patient hospitalization for any duration, commencing within 7 days from the date the injury was received.
   2. Results in a fracture of any bone (except bone chips, simple fractures of fingers, toes, or nose, or a minor chipped tooth).
   3. Causes severe hemorrhages or severe damage to nerves, muscles, tendons, or ligaments. (Note: Severe damage is generally considered to have occurred if surgery is required to correct the damage.)
   4. Damages any internal organ.
   5. Causes 1) a concussion or 2) loss of consciousness due to an impact to the head, or
   6. Causes second- or third-degree burns, affecting more than five percent of the body surface.
2. Results in property damage, other than the cost of the UAS, exceeding $500 to repair or replace the property or repair environmental damage.

In addition, the RPIC of the UAS is required to report an accident to the FAA within 10 days if it meets any of the following thresholds. HOWEVER, ACCIDENTS SHALL NOT BE REPORTED TO THE FAA OR NTSB PRIOR TO CONSULTATION WITH THE LBNL APOC.

1. At least serious injury to any person or any loss of consciousness. A serious injury is an injury that qualifies as Level 3 or higher on the Abbreviated Injury Scale (AIS) of the Association for the Advancement of Automotive Medicine (AAAM). The AIS is an anatomical scoring system that provides a means of ranking the severity of an injury and is widely used by emergency medical personnel. Within the AIS system, injuries are ranked on a scale of 1 to 6, with Level 1 being a minor injury, Level 2 is moderate, Level 3 is serious, Level 4 is severe, Level 5 is critical, and Level 6 is a non-survivable injury. The FAA currently uses serious injury (AIS Level 3) as an injury threshold in other FAA regulations.

Note: It would be considered a “serious injury” if a person requires hospitalization, but the injury is fully reversible (including, but not limited to, head trauma, broken bone(s), or laceration(s) to the skin that requires suturing).

2. Damage to any property, other than the small UA, if the cost is greater than $500 to repair or replace the property (whichever is lower).
3. Note: For example, a small UA damages a property whose fair market value is $200, and it would cost $600 to repair the damage. Because the fair market value is below $500, this accident is not required to be reported. Similarly, if the aircraft causes $200 worth of damage to property whose fair market value is $600, that accident is also not required to be reported because the repair cost is below $500.

Reporting to the FAA or the NTSB by the RPIC must be coordinated with LBNL APOC, the ASO, the Office of Science Aviation Safety Manager, and the DOE Office of Aviation Management.

The report may be submitted to the appropriate FAA Regional Operations Center (ROC) electronically or by telephone. Consult with the LBNL LBNL APOC prior to submitting an accident report to the FAA. The DOE Site Office Aviation Safety Officer will be notified prior to reporting to the FAA.

Once reviewed, and if reporting is required, electronic reporting can be completed at www.faa.gov/uas/. Contact the LBNL LBNL APOC prior to submitting an accident report to the FAA. The LBNL APOC will coordinate notification with the RPIC.

Reports can also be made by phone:

Reports may also be made to the nearest jurisdictional FAA Flight Standards District Office (FSDO). A list of FSDOs is found at http://www.faa.gov/about/office_org/field_offices/fsdo/

Regardless of the reporting option employed, the report shall include the accident reporting information listed above (10 items).

National Transportation Safety Board (NTSB) Reporting

In addition to the report submitted to the ROC, and in accordance with the criteria established by the NTSB, certain UAS accidents must also be reported to the NTSB. Contact the LBNL APOC for further information.

Appendix K. Responding to Suspicious UAS or Other Aviation Activity

LBNL pilots may fly in isolated or populated locations. In either case, they may encounter other UAS in their area of operation. The information that follows is aimed at providing a simple protocol for identifying and responding to suspicious UAS operations. Much of what is provided in the advisory applies in the context of security risk, but it could also include observation of unsafe flying, crashes, property damage, etc. LBNL pilots could also be subject to similar scrutiny by the public in areas where they conduct flights, and should be aware of the protocol.

Appendix L. Summary of U.S. Department of Energy COA

At-a-Glance Summary of the Class G – Public Agency sUAS COA

2021-ESA-9226-COA

The following information is provided as a summary of the current DOE COA. The COA is the governing document.

1. A copy of the COA must be available while flying UAS public aircraft for presentation to FAA or State and local law enforcement officials.
2. The COA holder is responsible for strict observance of COA terms and provisions.
3. The COA is effective January 5, 2022 through January 4, 2024 (subject to cancellation).
4. All operations will be conducted in compliance with Title 14 CFR §91 and the conditions of the COA.
   1. If you can’t comply, you likely need an additional waiver from the FAA.
   2. The reference to Title 14 CFR §91 is specifically stated on the COA.
5. Everyone involved with the UAS operations must read and comply with the COA.
6. Failure to comply with the COA is a cause for cancellation.
7. Airworthiness: UAS will be maintained in safe operating condition, including strict compliance with Airworthiness Safety Release.
8. The UA must be operated within visual line of sight (VLOS) of the Remote Pilot in Command (RPIC) and the person manipulating the flight controls at all times.
9. Must yield right of way to other aircraft, manned or unmanned.
10. Max altitude is 1200 feet above ground level (AGL) AND the UAS must remain in Class G airspace. Note: LBNL ordinarily limits max altitude to 400 AGL
11. Min visibility is 3 statute miles from the control station.
12. You cannot be RPIC for more than one UAS at a time.
13. No operation from a moving vehicle or watercraft UNLESS the operation is over sparsely populated area and the RPIC and VO are co-located.
14. PIC must make the UAS available to the FAA for inspection (and any associated documents)
15. PIC must conduct a preflight inspection to include specific aircraft and control station systems check to ensure the UAS is safe to operate.
16. A Distant (D) Notice to Airmen (NOTAM), must be issued per the COA.
17. Monthly reports per the spreadsheet provided by DOE-OAM are required, due no later than the 10th of each month following the reporting month (LBNL has its own spreadsheet for this purpose. See the COA for details). Reports must be submitted even if there are no sUAS flights during a given month.
18. Incident/Accident/Mishap Reporting is crucial. See the COA for details. We will route our reporting through DOE-OAM.
19. All UAS’s operated under the COA must be registered and marked per FAA.
20. Night operations are allowed but require special training and anti-collision lighting. The Aviation Safety Plan and work planning and control documents must include both before night operations may be conducted.
21. Minimum safe altitude operations:
    1. (Waiver from 14 CFR 91.119(b) and (c) is approved, as follows:
       1. Groundspeed must not exceed 100 mph (87 knots).
       2. May not operate a UAS over a human being unless they are directly participating in the operation of the UAS or are protected by a covered structure or stationary vehicle.
22. Do not fly in military training routes or special use areas without complying with directions provided in the COA.
23. Operations must only be conducted beyond the following distances from the airport reference point:
    1. 5 NM from airport with operational control tower
    2. 3 NM from airport with a published instrument flight procedure by no operational control tower
    3. 2 NM from an airport without an operational control tower and without a published instrument flight procedure.
    4. 2 NM from a heliport.
24. Emergency/Contingency Procedures

a. Lost Link

1. UAS lost link programmed to ensure no flight over people and landing in view of the RPIC
2. Rally and home locations programmed to remain within NOTAM area
3. Lost link procedures will not transit over populated areas, Victor airways or busy roadways or interstate highways.
4. Lost link procedures will remain within the operations area and altitude, avoid unexpected turn around or altitude changes and provide sufficient time to communicate with ATC if necessary.
5. Emergency/Fly away procedures:
   1. In an emergency, the RPIC will immediately contact ATC and state the nature of the emergency and pilot intentions.
   2. If you experience a UAS fly-away, advise ATC of the direction of flight, last known altitude and max remaining flight time.

Appendix M. U.S. Department of Energy Certificate of Waiver or Authorization: 2021-ESA-9226-COA (Complete COA)

Note: COAs are subject to periodic revision. The COA provided below is current as of the publication of this Chapter. It is advisable to contact the APOC to confirm the status of the governing COA.

Class G -Public Agency sUAS COA “2021-ESA-9226-COA (Complete COA)

Appendix N. LBNL’s Public Airspace Operations Declaration Letter

Appendix O. Constraints on the Use of Low Altitude Authorization and Notification Capability (LAANC)

If operating under FAR Part 107, FAR Part 107.51(B) states: the altitude of the small unmanned aircraft cannot be higher than 400 feet above ground level, unless the small unmanned aircraft:

1. Is flown within a 400-foot radius of a structure; and
2. Does not fly higher than 400 feet above the structure’s immediate uppermost limit.

HOWEVER, this only applies in uncontrolled airspace and does NOT apply if you receive approval to fly in controlled airspace via LAANC. All RPICs must understand the difference. If you use the LAANC system (most probably via a smartphone app) you can receive authorization up to the altitude limit shown in the grid square or the altitude you requested, whichever is lower. No additional altitude is approved regardless of what 107.51(B) says.

The image below makes it easier to understand. The image shows the LAANC overlay of the controlled airspace associated with the New Smyrna airport on the east coast of Florida.

Example:

The red checkmark indicates the location of the Ponce’ Inlet Lighthouse which rises to 175 feet’ MSL (about 165 feet’ AGL).  Notice that it sits within a grid square limited to 50 feet’. If one wants to fly an sUAS in that grid square, then one must submit a request via LAANC (up to 50 feet’ is all that will be granted). Once approval is received (usually 1-2 in minutes), one is cleared to operate up to 50 feet and and CANNOT go higher even if within 400 feet’ of the lighthouse because of being in controlled airspace.

Note: If operating in Public Aircraft Operator (PAO) status, the limits granted via the Nationwide Class G COA (or any other COA) apply as FAR 107 does NOT apply during PAO operations.

Appendix P. Future Forms and Exhibits (Reserved)

Appendix Q. University of California (“UC Drones”) Resources

The University of California Center of Excellence on UAS Safety is a comprehensive resource for information related to UAS. The Center remains up-to-date with the latest developments in FAA regulations and UAS technology.

LBNL pilots, flight crews and other interested parties are encouraged to visit the site.

Appendix R. Remote Identification of Drone UAS

Remote ID is the ability of a drone in flight to provide identification and location information that can be received by other parties. It helps the FAA, law enforcement, and other federal agencies find the control station when a drone appears to be flying in an unsafe manner or where it is not allowed to fly. Remote ID also lays the foundation of the safety and security groundwork needed for more complex drone operations.

Remote ID will provide information about drones in flight, such as the identity, location, and altitude of the drone and its control station or take-off location. Authorized individuals from public safety organizations may request the identity of the drone’s owner from the FAA.

All LBNL UAS pilots will be required to register their aircraft in accordance with the final rule on remote ID beginning September 16, 2023.

For the most up-to-date information regarding remote ID, to the FAA website at:

https://www.faa.gov/uas/getting_started/remote_id/

Appendix S. Interaction with the Public

Members of the public, when observing drone flights, may have responses ranging from mild curiosity about how a drone works to intense anger regarding perceived invasion of privacy. Remote Pilots in Command (RPICs) and Visual Observers (VOs) need to be prepared to handle interactions with the public.

The potential for such interactions may increase once drone operators comply with remote ID. ID will include publicly available information on the location of the RPIC. See Appendix R.

The first rule of such interactions is to not become distracted from RPIC or VO responsibilities. If approached by a member of the public during a flight, calmly let them know that you are engaged in piloting or observing a drone flight and that you need to focus your attention on that responsibility until the flight is complete and the drone is safely landed. You can provide assurance that you will be glad to speak with them after the drone lands. If warranted, advise them to move to a safe location until the drone has landed.

Once the flight is complete and the drone is secured, the RPIC should quickly evaluate the mental state of the individual. If the individual appears to be curious or non-confrontational, introduce yourself as a scientist from the Lawrence Berkeley National Laboratory and briefly describe the purpose of the drone flight. If the individual is curious about the flight, and the nature of the project allows it, answer their questions. Doing so will help provide additional information and present the societal value of your activity.

If, on the other hand, the individual(s) seem upset or belligerent, you can attempt to de-escalate the situation by presenting yourself in a passive, non-threatening manner and asking them to help you understand their concerns. If de-escalation does not work or if the person is armed or threatens to use a weapon against the flight crew or drone, the next course of action is to break off the interaction and leave the area. In rare instances it may be necessary to call for law enforcement assistance. In any case, the health and safety of all involved is paramount.

Appendix T. Richmond Field Station Practice Facility

The UC Richmond Field Station is available to LBNL pilots and crew members for practice and research flights. A formal process has been established for reserving flying time.

Go to the UC Drone FMS website. Users must sign up on-line, which will require establishing a user ID and password.

LBNL pilots must have a current FAA Part 107 Remote Pilot Certificate, an Aviation Safety Plan, and an approved WPC Activity prior to flying drones.

Appendix U. Remote Pilot Certification Renewal Program

The Federal Aviation Administration offers a free Part 107 Small UAS Recurrent Non-Part 61 Pilots (ALC-677) online course. This 3-module course, including a knowledge check test, replaces the $150 in-person renewal exam and satisfies pilot currency requirements for 24 months. This is not a replacement for the Part 107 Small UAS Pilot exam.

Once the renewal exam is successfully completed, a copy of the training completion certificate should be obtained and kept with pilots whenever conducting flight operations.

Appendix V. Current DOE and LBNL Aviation Safety Contact Information

Director, Office of Aviation Management. (Designated as the Senior Aviation Management Official (SAMO) for the Department of Energy)
Glen Wattman, Director, Office of Aviation Management/MA-30
U.S. Department of Energy, Headquarters, 1000 Independence Avenue S.W.
Washington, D.C. 20585
Email: glen.wattman@hq.doe.gov
Office phone: 202-586-5532

Office of Science (DOE Element) Aviation Manager (AvM):
Gus Fadel, Office of Science, Aviation Manager (AKA Aviation Safety Manager).
U.S. Department of Energy, Oakridge Field Office
200 Administration Rd, Oak Ridge, TN 37830, USA
Email: Gus.fadel@science.doe.gov
Office Phone (865) 576-0783

U.S. Department of Energy, Berkeley Site Office (Field Element) Aviation Safety Officer:
Michael Carr, Industrial / Construction Safety
U.S. Department of Energy, Bay Area Site Office
1 Cyclotron Road, MS 90-1023
Berkeley, CA 94720
Email: michael.carr@science.doe.gov
Office Phone: (510) 486-4296‬

LBNL Environment, Health, and Safety Division Director:

Maria G. Nappi
Lawrence Berkeley National Laboratory
1 Cyclotron Road Mailstop M/S 26R0143
Berkeley, CA 94720
Email: MGNappi@lbl.gov
Office Phone: 510-486-6571

LBNL Aviation Point of Contact (LBNL APOC):
Kevin E Goodwin
Lawrence Berkeley National Laboratory
1 Cyclotron Road Mailstop M/S 78R0101
Berkeley, CA 94720
Email: KEGoodwin@lbl.gov
Office Phone: 510-486-5176
Mobile Phone: 510-708-8503

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